February 12, 2014

EMIR Trade Reporting | In Case of Emergency Break Glass

If you are a firm who is not yet prepared for reporting all derivatives (that means ISDA OTC and Exchange Traded) to a Trade Repository, here's some emergency steps you can take:

  • Finalise your TR choice quickly by comparing prices between UnaVista, DTCC, Regis-TR and KDPW
    • Estimate the volume of new OTC & ETD trades, plus lifecycle events
    • UnaVista:
    • DTCC:
    • KDPW:
    • REGIS-TR:
    • ICE Trade Vault:
    • CME TR:
  • From a regulatory point of view it makes no difference who you choose – once you start reporting you get a tick in the compliance box
  • From a technical perspective: how quickly can you create a CSV file with your data, and load it manually into your chosen TR? Pick the lowest automation route to get going – a spreadsheet upload will achieve compliance, even if done via their a web GUI
  • Commercially: Using your volume assumptions, and any complexity around the number of entities you want to report for, make a simple XL spreadsheet and compare prices
  • Do not attempt to provide delegated reporting until you achieve your own compliance
  • If you choose to delegate
    • Will your chosen partner take on reporting your entire portfolio?
    • If not, you'll need multiple delegated parties
    • How do you know they've accurately completed the job? You'll need to receive an output file to rec back to your own books and records for each delegated relationship
    • Is delegating any easier than creating your own CSV file and manually uploading?
  • Accuracy is less important in the short term than quanitity and scope: build a feed and get going, meet the validation rules of your TR, the rest can wait
  • TR to TR matching will be a medium term problem: given the late breaking ESMA requirements, and the apparent lack of readiness by many firms in Europe, the results of your matching with other TRs will be something of a tortoise and hare problem: be a tortoise as it isn't going to get fixed quickly
  • Ask for help, OTC Space and other firms have the expertise to get you off the starting blocks very quickly



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