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