Canadian OTC Derivatives Trade Reporting Obligations: What Steps Should You Take?

On March 14, 2014, the International Swaps and Derivatives Association, Inc. (ISDA) published Canadian Representation Letter #1: Trade reporting and Other Obligations, a copy of which can be found [here]. The purpose of this Representation Letter is to assist market participants in addressing their obligations under the over-the-counter derivatives trade reporting rules in Canada. To date, each of the Ontario Securities Commission, the Manitoba Securities Commission and the Autorité des marchés financiers have published their own respective Rule 91-507 Trade Repositories and Derivatives Data Reporting. Reporting obligations under these rules begin on July 2, 2014 for trades involving a clearing agency or a dealer and on September 30, 2014 for trades that do not involve a clearing agency or a dealer.