EMIR compliance dates moved

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Patrick Pearson (Head of the EU Financial Market Infrastructure Unit) and David Bailey (Acting Head of Market Infrastructure & Policy, UK FSA) both spoke at the TradeTech conference on Monday and made emphatically clear that the target date for compliance with EMIR is not 1st January 2013. The new dates stated by David were:

  • Clearing from 1H 2013
  • Reporting in 2H 2013
  • Trading (OTFs) in 2014

Both Patrick and David were keen to emphasise that the challenge to get the European capital market participants to comply with rules not published until end of Sept 2012, within three months (by Dec 31st 2012) isn't realistic.  Whilst I wouldn't suggest ignoring EMIR during the Summer (during which ESMA will be looking for feedback on draft rules), it's not quite the big rush we all expected. Patrick also hinted that pushing firms to comply with Dodd Frank and EMIR, in advance of similar moves in the the G20 countries outside the EU or US, may cause regulatory arbitrage, and need an adjustment to the G20 deadline of Dec 31st 2012. Click the diagram to view in widescreen. The end dates of the triangles are implied from the wording above, given at the Conference.

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