ESMA issued an updated timeline (indicative) on May 22, 2013. Emphasis is placed on the fact of the Trade Repository (TR) registration process and the impact on the earliest reporting start dates. ESMA itself doubts the indicative reporting start date due to the delayed registration process for trade repositories. Currently we are aware of seven trade repositories which have announced their interest in becoming authorized by ESMA!
According to EMIR legislation, Sep 23, 2013 has been tentatively defined as the starting date for the first wave of reporting requirements. Interest rate and credit derivatives must be reported to a TR. What are the main concerns in order to comply with this deadline? What difficulties are you already aware from an implementation point of view?
Entities must apply to ESMA and be registered or recognized by ESMA as a TR in order for firms to be able to use them to meet the reporting obligation under EMIR. Below is a list of entities which have publicly announced their intention to seek registration or recognition as a TR from ESMA:
When EMIR came into force in mid March 2013, one of the first obligations for NFCs (non-financial counterparties) was to notify their respective national authorities (for EMIR) and ESMA about the clearing thresholds, i.e. corporates have to report whether they exceed the clearing threshold as of March 15, or fall below it.
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