Regulation
Reporting is a key component of any company’s compliance with EMIR and ensuring the report is correct and submitted on time is the responsibility of the counterparty, though this can be delegated. Other than reporting, there are key risk mitigation requirements laid in place by EMIR which require clear established processes to be compliant. Reconciliation frequency is dependent on the number of trades the company has with each of its counterparties and whether it is above or below the clearing threshold. For most non-financial counterparties under the threshold the frequency is; once per quarter for counterparties with more than 100 OTC contracts outstanding, once per year for less than 100 OTC contracts outstanding. Although not a common process, the regulation mandates that counterparties have auditable procedures in place to be able to reconcile, manage, identify and monitor the risks associated with the dispute process. The capability to calculate your current position relative to the clearing thresholds for each asset class is also mandated by the regulation so you can provide evidence that you do not exceed it. (1billion EUR Equity/Credit, 3Billion EUR Commodity, Interest and Foreign exchange.) This is also useful for internal use.
Solution
Our solution for these regulatory issues is Subscribe to EMIR (S2E), a web-based platform that can facilitate full compliance with the EMIR regulation. S2E enables the possibility to automate the whole reporting process from receiving the trade data through to the trade repository. In our case this is REGIS-TR, which we have a close connection with. It is already fully up-to-date with the recent changes to the regulation that came into effect on the 1st November 2017. In addition, both trade confirmation and clearing threshold checks can also be automated fully. Reconciliation and dispute management processes are streamlined and have clear workflows in place which make for ease of use internally and also makes the process fully auditable.
Our Service
S2E is a web-based solution which we can quickly onboard in your company without disrupting your current IT systems or treasury operations. The onboarding is comprised of setting up the database, linking the solution to existing systems and training your employees in the use of the system. We also offer a number of services in addition to S2E and ongoing customer support. In the case that you are not familiar with what exactly the EMIR regulation means for your company and whether you are currently compliant we can offer an EMIR readiness consulting. This comprises of 2 days on-site assessment of your compliance activities, and a report at the end providing you with a clear picture on your overall compliance with EMIR and steps that need to be taken in order to ensure full compliance. We also offer third-party reporting services to further reduce the strain of transaction reporting.