We've got multiple EMIR reporting implementations going on right now and its worth commenting on the current state of EMIR trade reporting.

After having done a ton of Dodd-Frank reporting implementations, I can tell you that EMIR is turning out to be a bigger headache. Anyone care to put out an over/under on the Feb 12th deadline slipping? Here’s whats working against that deadline.

TR’s are only partially ready. This was the ultimate cause of the delay in the US for D-F.  One of the SDRs was just not ready to go.  Some of this is not their fault. After the surprise ETD ruling ESMA has only recently provided guidance to the TRs on what data points they need for ETDs. TRs and participants alike were waiting eagerly for the guidance and now are running hard to try and put the necessary data together.

Some TRs have certain product types that are just not working correctly. At least one of the TRs is not currently able to accept any IR trades. We’ve noticed a similar amount of general TR production issues that we saw in the US just prior to go live. Its a pain in the neck but we will deal.

At the end of the day I will go as far as to say that the joke is on ESMA. Looking across all the TRs there is virtually no harmonization. Not only are the data fields significantly different, but a general lack of data validation. Want to sent a Brent trade? Look for “Brent” or “BRT” or “Brent Crude” etc. Enjoy making sense of that on the back end. Really only one TR doing a good job of data validation.

So what may cause the Feb deadline to stick?  Herculean efforts by participants and TRs…right now ESMA seems uninterested.