The dust is beginning to settle after the passing of the EMIR trade reporting deadline and many of our sell-side clients are getting to grips with the initial teething issues around data flows and data quality.
Of course, in Europe, this is only the first step on the road to far more comprehensive reporting and monitoring. Given the scale of work that has been needed to get ready for 12th February, it’s unsurprising that many firms, especially on the buy-side,
have not yet taken a detailed look at the mid- to long-term additional requirements and associated challenges.
Today, some of the difficulties we’ve heard about for firms reporting have included proper establishment of LEIs, alignment on generation of UTIs for OTC trades, technology issues with sending and receiving data, etc.
As these problems are knocked down, we think that some of the future challenges that will become more apparent might include:
- One-sided reporting of trades on the buy-side, with the other side going to a different TR
- Robust exception identification and management for smaller firms
- Inter-TR recs
- Reconciliations between the various parties along the trade ‘chain’
- The apparent lack of appetite from brokers and banks to provide delegated reporting (and associated services)
Our view is that many on the buy-side have been somewhat shielded from the effects of EMIR TR reporting and that as the regulations developed and evolve, these same buy-side firms could find themselves unprepared.
So, what to do? We believe key issues will include:
- Having tools and processes (i.e. systems) that will help manage the static data for LEIs and counterparties, instruments and asset classes
- Solving the UTI generation capability or at least some agreed rules around UTI generation
- Provisioning a flexible yet robust reconciliation capability (possibly outsourced) to close the gap between different sides and sources.