EMIR OTC Trade Reporting Officially Delayed Until February 2014

Keep your betting pools going on the EMIR Trade Reporting deadline. EMIR has officially moved the reporting deadline from Jan 1st 2014 to February 12th 2014 due to delays in approving official Trade Repositories (TR). Apparently some of the TR’s didn’t fill in their applications correctly.  Um…sure…if you say so ESMA. I’d say the delay is more likely in implementing the specifics of how the data will be captured, represented and maintained for regulatory reporting.

The reasoning for delay may be unclear but what can be said with certainty is like all initiatives around moving complex data, it is relatively easy to draw out high level principles but significantly more challenging to iron out the details. Participants should not take this delay as a sign to breathe easy and relax their reporting efforts/projects. Use the delay to iron the next level of details…how will your firm manage to report required information that is nowhere in your systems?  e.g. If your firm falls in the NFC+ category, then you must report collateral (per trade or per portfolio/counterparty). It is likely that this information is in a separate system than your main trading system so some data staging and preparation is required before sending to the TR.

Lastly, as the TR details are ironed out, changes will occur to the specific data requirements for participants. My suggestion is to not build a solution entirely based in code so you don’t have to spend countless man-hours reworking it to meet changing requirements. Or be really smart and buy what already works. (warning – shameless plug!)