It is now one week since “Remit reporting phase 2” started, on 7th April. From that date, any new off venue reportable trade needed to be reported to ACER via a Registered Reporting Mechanism (RRM), including some that must be reported by the end of the working day after execution.

ACER have published this press release announcing the start of reporting, and reminding the market that the different NRAs (National Regulatory Authorities) will be monitoring compliance and enforcing it if necessary. This article on the ICIS web site also provides some post go live comment.

While the deadline has passed, there are still some milestones remaining:

• May 7th – the first deadline for the reporting of non standard contracts struck on 7th April – these must be reported within a calendar month of execution.
• July 6th – the backloading deadline – by which time any contract/trade open on the 7th April must be reported.Once a framework  contract is reported,  “Child executions” of those contracts will also become reportable within the appropriate time-frame.

Once reporting is live, the question arises as to regulatory focus, and what, if anything should be the focus of continuing compliance efforts. This post on the CTRMCenter web site considers the question, and notes the increased importance of monitoring. This arises not only because NRAs now have data with which to monitor under REMIT, but also because of the Market Abuse Regulation (MAR), which comes into effect on 3rd July.