Congrats to those who went through this major milestone without experiencing any reject from the Trade Repository! Our clients using FinTeX Factor:y solution had to deal with some rejects on ETDs valuation concerning the stock of open positions reported in EMIR legacy version that must continue to be kept alive (Valuation update, Modification, Exercise, aso.). Like them, you certainly faced similar problems with stock transactions (sometimes in a large proportion) that required to be updated at the Trade Repository to ensure they continue to be reported correctly (Valuation in particular). And although the regulator tolerates a 180-days period to make the stock compliant (ITS Article 10(2)), the flexibility and agility of Factor:y allowed our clients to fix these issues right after go-live, as our solution allows them to send the necessary update events quickly and effectively.

Didn't you get a headache wondering how to populate Field 2.4 "Subsequent Position UTI"? The complexity comes from the fact that EMIR REFIT has introduced dependencies between reports. For example, some particular types of transactions such as novation or compression must refer to the UTI of the initial transaction. Similarly, the “Inclusion in a Position” concept, which is almost generalized for ETDs, imposes that any transaction must refer to the UTI of the position in which it is included. A potential difficulty for those who have to aggregate data (transactions and positions) from different information systems. Factor:y by FinTeX relies on a comprehensive and normalized data model which makes this kind of obstacle much easier to overcome!

“Third Country Organized Trading Platform”, this is a key point Knowing whether the trade was made on a “Third Country Organized Trading Platform” is one of the key points of EMIR REFIT reporting, because it has an impact on several fields, starting from field 3, "Entity Responsible for reporting", 2.29 "Confirmed", 2.30 "Cleared obligation", 2.37 "Intragroup", to the most famous one, field 2.8, the UPI ! As of today, there is no clear answer, even from the Trade Repository. The reason is that ESMA provided a mapping file which was not precise enough, as based on the Exchange common name rather than its MIC Code (https://www.esma.europa.eu/sites/default/files/library/equivalent_tc-markets_under_emir.pdf). From our standpoint, the “Third Country Organized Trading Platform” notion is to avoid having to populate these fields and in particular the UPI for non-isinized ETDs (especially on american markets). But we are waiting for confirmation of our interpretation from ESMA. Did you come across the same issue? #EMIRRefit #EMIR #REFIT #TransactionReporting #RegulatoryReporting #RegulatoryCompliance #Regtech #PortfolioCode #UTI #UPI