Today, the European Securities and Markets Authority (ESMA) published its 20th Questions & Answers (Q&A) guidance on the European Market Infrastructure Regulation (EMIR). The updated Q&A includes one new question which clarifies a number of aspects related to the transition to the revised technical standards on reporting, which will become applicable on 1 November 2017. The added question is listed below:
TR question 44
a) Will the counterparties be obliged to submit reports to update the old outstanding trades upon the application date of the revised technical standards? If so, will those reports have to be submitted in accordance with the revised standards?
b) How will the reports related to old outstanding trades be validated?
c) How the counterparties should report updates related to the outstanding complex derivatives, in the case where they were reported in one report with a single UTI but would be expected to be decom-posed and reported in more than one report under the revised rules?
d) Are the expired trades expected to be updated? If so, how will the reports relating to the expired trades be validated?