As we have mentioned in a previous blog post, ESMA has issued a call for evidence for the Simplification of Financial Transaction Reporting.
MAP FinTech has carefully studied ESMA’s proposals and has replied to the call for evidence. In the spirit of alleviating our clients from duplicative reporting , streamlining reporting regimes and achieving maximum harmonisation with other financial centres, our proposals to ESMA can be summed as follows:
- Report Once principle: A single report, for all reporting obligations under Art.9 of EMIR (to TRs), Art 26 (to ARMs or NCAs), Art. 6,10,20 and 21 (APA) of MiFIR and Art.4 of SFTR.
- Harmonised reporting template for the Reporting Once principle.
- Extension of the deadlines to report under Art. 26 of MiFIR, Art.9 of EMIR and Art.4 of SFTR to T+2.
- Abolish dual sided reports.
- Exemptions from reporting for small Financial Counterparties (e.g. Investment Firms, Funds, etc.) on the basis of operational complexity, size, exposures etc. (small buy-side Firms).
- Exclude ETDs from post trade events reporting, i.e. no valuation or collateral updates for Exchange Traded Derivatives ( Exchange Traded Derivative has the same meaning as EMIR).
Read our feedback here.
Disclaimer: This blog was written by MAP FinTech’s Market Infrastructure Team and under no circumstance does it replace advice or guidance by Firms’ compliance and/or risk management functions. Firms affected by the topics discussed in this blog should consult with their compliance/risk management personnel and or consultants for specific guidance and must not rely on the information contained herein.
Contact our team of experts for more information or any assistance you may require.