MAP FinTech Webinar – In anticipation of the EU EMIR REFIT launch

MAP FinTech hosted a webinar with its EMIR-obliged clientele a few days before the REFIT go-live date to better prepare reporting entities. MAP FinTech staff reiterated to reporting entities that, when reporting on a delegation basis on behalf of other financial institutions (such as investment firms, credit institutions, funds etc.) defined under EMIR as Financial Counterparties (FCs), they need to furnish their Trade Repositories (TRs) with the LEI and a contact email for the said FCs.


Trade Repositories need to obtain explicit authorisation by delegating parties

As per the requirements of EMIR REFIT, TRs will need to directly contact delegating parties asking them to confirm in writing that they have authorised the reporting entities to submit EMIR reports on their behalf. Failure by the delegating parties to provide explicit confirmation will result in the rejection of reports submitted by report-submitting entities on their behalf.

TRs have begun reaching out to delegating parties from early April 2024 and urged reporting entities to inform all those concerned to take prompt actions. Finally, for non-financial counterparties for whom the reporting entities are liable to submit EMIR reports on their behalf, the reporting entities can self-certify that they have received the authorisation to report without the need for the TR to directly obtain the explicit confirmation.


UPI population status update

On the issue of generating UPIs, MAP FinTech informed reporting entities that as per ANNA-DSB, the authority issuing UPIs, as of early March 2024 about 1,148,000 UPI records were generated. However, from an analysis conducted by ANNA-DSB, only 300,000 were generated by Market Participants; the rest were populated by ANNA-DSB themselves from the record they have of OTC unlisted derivatives that were issued with an ISIN. It was emphasised to webinar attendees that a UPI must be available on the reporting day. Therefore, attendees must examine their OTC derivatives’ offerings and try to identify the suitable UTI from ANNA-DSB’s database. In cases where the necessary UPI does not exist, reporting entities need to generate it. You can refer to MAP FinTech’s blog on the technical aspects regarding the generation of a UPI.

Testing of the new regime MAP FinTech readiness and troubleshooting

MAP FinTech informed the audience that it has carried out extensive testing of the new reporting regime and has identified discrepancies and inconsistencies in the XML schema and ESMA’s validation rules that caused reporting breaks. These were addressed to the TRs and ESMA who have provided intermediate guidance on how to overcome these issues.

Furthermore, MAP FinTech informed clients that, as of the beginning of April the overwhelming majority of its clientele had already provided the necessary additional data for the REFIT reporting regime and those were successfully incorporated into the new reports and were tested in a UAT TR environment.


New tools for EMIR-REFIT

In closing, participants were reminded that MAP FinTech offers new tools to assist its clientele, namely the UPI Link search tool that identifies issued UPIs from ANNA-DSB’s database, and XMLCon.Vert service that allows clients to convert .csv files to the requisite REFIT XML format.


MAP FinTech: your trusted RegTech Provider

Looking ahead, MAP FinTech pledges continuous monitoring and support post-launch, anticipating an adjustment period and committing to random reconciliation checks to uphold data integrity. Clients are urged to vigilantly monitor submissions and report any anomalies during the initial weeks.

As the countdown to this pivotal milestone accelerates, the synergy between MAP FinTech, clients, and TRs assumes paramount importance. With unwavering dedication to facilitating a seamless transition, MAP FinTech expresses gratitude for the collective effort of all stakeholders, confident that this complex undertaking will ultimately yield more efficient reporting processes under the new EMIR REFIT standards.

At MAP FinTech, we offer more than just cutting-edge technology; We provide expert knowledge and unwavering support to guarantee a seamless transition to the new reporting requirements. Contact our team of experts today and experience a smooth transition.

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