It's been barely six weeks since the EMIR trade reporting
obligations came into effect on 12 February and, as the regulatory
dust begins to settle, parties to derivative transactions are still
in the process of assessing their duties under the new
regime. In the lead up to the February deadline, bank and
securities firms were busy implementing their client outreach
programmes whilst we were busy putting out client alerts and blogging about the new requirements under
EMIR. We continue to help clients with their questions on
this significant change to the EU regulatory landscape.
Two aspects of the new trade reporting regime in particular
repay some close attention to avoid potential trip-ups.
First, the rules relating to what has been termed
'backloading', or, in other words, the requirement to
transaction report historic trades. After some uncertainty in
the lead up to implementation, the requirements are now
clearer. Broadly, counterparties need to ensure that
