12 February 2016 marked the two year anniversary of EMIR trade reporting. The ongoing flurry of EMIR events reminds us all that the recently completed Data Harmonisation Level 2 (L2) initiative was a necessary step in preparation for ESMA’s impending EMIR technical standards (RTS/ITS) rewrite (currently with the European Commission for consideration and adoption).
Guided by our Service Delivery teams, Abide Financial’s EMIR reporting clients have enjoyed a very positive experience in respect of L2 planning and implementation.
- Abide Financial clients received a proprietary synopsis of required reporting updates
- An Abide ‘sandpit’ environment connected EMIR clients to the TR test system to facilitate end-to-end submission testing ahead of the L2 deadline Service Delivery representatives analysed specific client data and provided bespoke reporting analysis, including Abide and TR validation error correction
- Ad-hoc L2 consultancy offered advice and provided guidance on the consequences and implementation of EMIR reporting changes; and
- All EMIR clients received a post L2 summary with an action plan for correcting any unresolved errors.
The EC has yet to set the implementation date for the EMIR technical standard rewrite though current market projections of Q1 2017 seem realistic (and potentially as early as 12 February 2017).
To encourage clients to take action in readiness for the EMIR rewrite, Abide Financial’s Professional Services and Service Delivery teams have already completed an initial assessment of the impact of proposed revised and new technical standards. Highlights of this analysis can be found here.
Priorities for trade repositories (TRs)
ESMA also recently published its 2016 supervisory priorities for TRs, as well as its annual report summarising key supervisory work and actions undertaken in 2015. The timing of the report serves as a gentle reminder to us all that EMIR reporting requirements continue to evolve and that TRs and reporting entities need to adapt and plan implementation schedules accordingly. For example, reporting entities will, in all likelihood, need to amend EMIR reporting data files significantly to accommodate 129 EMIR fields, with just twenty-five of the original EMIR fields remaining unchanged.
Over the next 12 months, ESMA’s focus is on:
- Data quality
- Data access
- Financial risk
- Information security risk
To illustrate the status of ESMA’s 2016 supervisory priorities, where European institutions need to take action and for ease of reference, Abide has created scorecards for data quality and data access:
Abide Financial will track ESMA and EC announcements closely in respect of the Delegated and Implementation Acts that will set new EMIR technical standards in stone. In the meantime, we encourage all reporting firms to take action now to put in place the appropriate plans and processes to ensure that they will be ready in good time to comply with new EMIR reporting obligations.
Abide Financial’s PROXIMITY programme
Understanding and managing the complexity of new reporting obligations under the proposed EMIR Rewrite presents an enormous challenge to all reporting firms and particularly those entities that find themselves subject for the first time to regulatory reporting obligations.
Eligible firms must determine whether they have sufficient expertise to evaluate evolving reporting requirements effectively themselves and the right resources to expand or adapt internal systems and processes to deploy an effective and compliant solution to multi regime, multi jurisdiction transaction reporting obligations.
Alternatively, firms may choose to partner with an external service provider focused exclusively on understanding and managing the impact of regulatory change on transaction reporting processes, and to manage end to end reporting processes for multiple regulatory regimes and reporting destinations.
Abide Financial’s PROXIMITY programme helps reporting parties to manage the challenge of the EMIR Rewrite, as well as MiFID II/R and other regulatory reporting obligations, combining a systematic and guided approach to meeting regulatory reporting timelines with an established, end-to-end implementation, technology, operations and compliance ecosystem.
In essence, we tell you what you need to do (to comply), do it for you (taking and transforming reportable trade data to meet all regulatory obligations), then tell you what we’ve done (tailored client reporting).
Clients benefit from a fully managed process that takes the pain – and effort – out of untangling the complex web of diverse (and changing) reporting requirements and mitigates the risk of reporting failure as new rules come in to effect.
- Experience – knowledge gained from extensive EMIR and MiFID I client onboarding
- Expertise – implementation of complex, multi regime reporting requirements
- Efficiency – optimised operational resources; reduced cost of compliance
- Guidance – managing operational, compliance and technology risk across reporting regimes
- Infrastructure – proven reporting environment and end to end processes
The starting point of every Abide engagement is a no-obligation consultation with a transaction reporting specialist and free ‘regulatory health check’. Contact us now for an in depth conversation about preparing for EMIR, MiFID II/R and other regulatory reporting challenges.