Not sure if you noticed this but Tuesday (June 25th) came and went and not a single trade repository was registered by ESMA. And so the indicated reporting start date for interest rate and credit derivatives of September 23rd is not achievable anymore.

Interesting to see how a footnote changes the perception of market participants and re-writes reality… :)

So, November it seems likely to be – but, keeping in mind that there are rumors of up to 16 applications of potential trade repositories and only so many EMSA staff to work on them, also keeping in mind that IT frozen zones at that time of year are fast approaching and hearing whispers on conference calls that indicate an even later reporting start date… Well, it might just be 2014 before the reporting requirement actually sets in.

Should you now go on a well-deserved summer holiday? Not so fast – other dates are approaching fast, e.g.

• Deadline for Frankendodd cross-border exemption (July 12th)
• Clearing start date for Frankendodd category III market participants  (September 10th)
• Risk mitigation techniques for bilateral trades under EMIR (September 15th)

And really, are you not just right now sighing a breath of relief that you gained a precious few weeks to get that reporting requirement in place and thoroughly tested. And don’t we have now at least half a chance to see either ESMA or the industry decide on a few crucial things on EMIR reporting like UTI generation, UPI taxonomy, or correctly filling in legs and currencies.

Stay tuned… it keeps getting more interesting and exciting by the day…