EMIR Refit | Navigating the Details

As preparation has started for EMIR Refit, many regulatory reporting teams are cross-functional and may be involved in implementation of various regimes including MiFIR and EMIR. Whilst familiarity of multiple reporting regimes may be of benefit in aiding understanding of the requirements, there are some distinct differences between seemingly similar fields and the expectations of the required data. Therefore, it is important to be aware of the differences when navigating the details.

Reporting FX Swaps Within One Transaction Report

When traded on a venue, FX Swaps are traded as two Forwards therefore two separate transactions are concluded on the venue. In the subsequent MiFIR transaction report, FX Swaps are represented in two separate transaction reports (one for the near leg, the other for the far leg), linked by a complex trade ID.

In EMIR Refit, the guidelines clearly state that FX Swaps should appear in one transaction report therefore removing the need to separate into two and linking with a Package Identifier. The variation as to how FX Swaps are captured in a firm’s internal booking system have led to problems in the past with completing the transaction reports correctly. Therefore, aligning trade booking/capture systems with each reporting regime adds another layer of complexity to reporting.