Skip to content

O’Malia : it’s all about the data

Scott O’Malia continued what is fast becoming his “Look, the Emperor’s naked!” tour with a speech this week at the London School of Economics. His latest critique focuses on technology (or the lack of it), an area where the CFTC is known to be weaker than other regulators, who are merely presumed to be technologically […]

Better Late Than Never: CFTC Consults on Swap Data Reporting Rules

Better Late Than Never: CFTC Consults on Data Reporting Rules Long aware of the need to improve its data collection and quality standards, on 19 March 2014 the Commodity Futures Trading Commission (CFTC) published a request for public comment on Part 45 of its Swap Data Reporting rules. Part 45 requires the real-time reporting of […]

FCA Reporting- we haven’t gone away

The FCA yesterday updated its transaction webpage with a reminder to all firms that trade reporting under EMIR does not replace its own reporting obligations. Firms should continue to submit FCA transaction reports using an Approved Reporting Mechanism (ARM) in accordance with SUP 17 of the FCA Handbook. While this is merely a reminder of […]

LEIs: First Part of Common Data Format Published

On 24 February 2014, the Regulatory Oversight Committee (ROC) of the global legal entity  identifier system (GLEIS) published the first part of a common data format to be used by pre-LOUs as a standard for sharing or publishing data in the interim GLEIS. The work is designed to provide a framework to support the initial […]

EMIRacle needed- 12th February Reporting Mandate

Trade reporting under EMIR begins today. The FCA’s optimistic survey notwithstanding- there may be trouble ahead. While the larger banks and financial institutions are (relatively) well-prepared, there is widespread concern by both regulators and market participants that the sudden gear change will be far from smooth. The reporting obligation is mandated in Article 9(1) of […]

FCA Publishes EMIR Factsheets

On 10 February 2014, the Financial Conduct Authority (FCA) published two factsheets relating to EMIR: EMIR reporting – is the industry ready?  This is drafted for those looking to comply with the EMIR reporting obligation.  It concludes that most firms will be reporting their derivatives contracts from the start date of 12 February 2014 and […]

Further Light Shed on EMIR Trade Reporting?

Law firm Simmons & Simmons has provided an interesting update on EMIR reporting obligations for fund managers. A non-EU Alternative Investment Fund (AIF) will be obliged to report trades under Article 9 of EMIR from the point at which its investment manager becomes authorised or registered under the AIFMD.  Whilst stressing that confirmation from ESMA […]

Upgrade Needed to ISDA/FOA Reporting Delegation Agreement?

To date, much of the discussion surrounding the ISDA/FOA Reporting Delegation Agreement has focused on whether the document is balanced in its allocation of risk between sell-side and buy-side.  However, today, a new factor was introduced when the Futures and Options Association (FOA) notified members that it has received confirmation that the FCA regards the […]

ISDA Publishes EMIR Delegated Reporting Agreement

Introduction On 13 January 2014, ISDA and the FOA published their jointly drafted ISDA/FOA EMIR Reporting Delegation Agreement (the “Agreement”), designed to help market participants meet their obligations under Article 9 of EMIR by providing a bilateral standard form contract which can be used to document delegated reporting arrangements. The Agreement Under the Agreement, an […]

Footnote 88- contentious, confusing, and counter-productive

ISDA has published a survey assessing market fragmentation and liquidity dissipation consequent upon confusion and uncertainty surrounding the controversial Footnote 88. The footnote expands the scope of the SEF mandate to effectively include all electronically traded OTC derivatives, obliging even those platforms that do not trade “required products” to register and their clients to abide […]

Press enter or esc to cancel