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: http://www.lseg.com/areas-expertise/post-trade-services/matching-and-reconciliation
  • DTCC: http://www.dtcc.com/data-and-repository-services/global-trade-repository/gtr-europe
  • KDPW: http://www.kdpw.pl/en/Trade%20Repository%20EMIR/Pages/default.aspx
  • REGIS-TR: http://www.regis-tr.com
  • ICE Trade Vault: https://www.icetradevault.com
  • CME TR: http://www.cmegroup.com/trading/global-repository-services/cme-european-trade-repository.html
• 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