EMIR ETD | “Belay That Order”

News made the rounds last week that ESMA was holding off on requiring ETD deals be reported to TRs until sometime in 2015.  Good news, I guess.   Leading up to this un-official decision you may have found yourself in the following situations:

Belay That Order
Belay That Order

-Trying to convince certain executives that EMIR is a “real deal” and that it’s much larger in scope than Dodd-Frank (including self-reporting of ETD deals).

-Asking (in the way of asking that is more like pleading) for your FCMs to consider sending your ETD deals to the TR on your behalf.

-Listening to the FCM politely tell you how much they appreciate your business and politely decline to send trades to the TR for you.

-Sitting in a conference room discussing at length what the ESMA decision (as yet unofficial) actually includes.  Does it include cleared swaps?  Does it include Forwards?

Our take.  Everything is at a full rumor state right now.  Until we see something that is “official” it’s subject to change.  But here’s what we know:

Two of the major exchanges are already “strongly indicating” that they will be sending transactions done on their exchange to the TR’s on behalf of their customers.  Our take is that this is highly probable and other exchanges will be forced to do the same to remain competitive.   So while the delay is good news, it is very likely to turn out to much ado about nothing.  We know one of the exchanges is already in process to do this immediately.    This is obviously an area to watch closely, but our take is that the exchanges are already stepping up to the plate.

As far as convincing executives that EMIR reporting is a real deal?  Keep up the good fight.