The European Association of CCP Clearing Houses (EACH) welcomes the opportunity to provide feedback to the ESMA First Report for Consultation “Technical standards on reporting, data quality, data access and registration of Trade Repositories under EMIR REFIT”. Some of the highlights of the EACH response include:
- Risk and Reporting – EACH Members believe the foundation of the proposed amendments to EMIR should concentrate on risk and reporting and should only include the data essential for regulators to monitor systemic risk. New obligations and fields which are not essential to risk oversight place a disproportionate burden on reporting firms. Similarly, the reconciliation process needs to limit, and not increase, its scope to focus industry efforts on the reports and fields that matter most to regulators’ priorities for risk oversight.
- New obligations – EACH Members find that new obligations such as mandatory notifications and break resolution proposed for reporting firms need to be proportionate and based on a risk-based approach to be effective. It is important for ESMA to understand that the root causes of current EMIR matching challenges relate more to inconsistent reporting policies and interpretation rather than unintended “errors” and poor data quality. We have made suggestions on the reconciliation and break management process to facilitate addressing reporting differences that arise.
- New fields and data standards – EACH Members have advocated their views on UTI, UPI, LEI and ISO proposed standards and have commented on new fields proposed for inclusion in EMIR.
- EACH Members welcome increased guidance for EMIR and suggest ESMA works collaboratively with the industry to provide more extensive guidance and worked examples of reporting for CCPs and clearing participants. In particular, it is important to clarify how to report the new action types, fields and lifecycle events and distinguish between ETD and OTC reporting as the data elements in the CDE guidance were designed for OTC reporting.
For more information, please find attached the EACH response or visit our website www.eachccp.eu