FIA has responded to a joint consultation paper issued by the Financial Conduct Authority and Bank of England regarding changes to reporting requirements, procedures for data quality and registration of Trade Repositories under UK EMIR. The consultation sets out proposals relating to measures for mandatory delegated reporting requirements, counterparty notifications and reconciliations processes and the use of XML schemas and global identifiers based on the adoption of recommendations from the Committee on Payments and Market Infrastructures the International Organization of Securities Commissions on Critical Data Elements (CDE).
In its comments, FIA noted that:
- Applying the same rule set to both OTC products and exchange traded derivatives "fails to account for the nuances between these derivative classes."
- The classification of futures and options executed in third-country, non-equivalent markets as OTC for reporting purposes "may lead to some data being omitted misreported or reported inconsistently"
- FIA and its members request more guidance on accurate reporting of the "execution timestamp" field as ETD positions are netted through end-of-day processing and not executed on the market.
