The European Association of CCP Clearing Houses (EACH) has published a paper
on trade reporting under the European Markets Infrastructure Regulation (EMIR).
The paper aims to provide the European Securities and Markets Authority (ESMA)
with recommendations to address some of the key implementation challenges that
the EACH working group has identified.
The key challenges are that:
- trade level reporting alone will not provide ESMA with complete data;
- reporting by both counterparties leads to increased numbers of trade records, greater aggregation challenges and implementation costs;
- market dependency on end of day netting and valuation events by CCP; and
- differences exist between OTC-Cleared and ETD trade workflows.
It also provides details of how EACH intends to implement trade reporting in line
with current EMIR regulations.