Sftr Master Regulatory Reporting Agreement

For SFTR, as of 11 October, the buy-side is responsible for the declaration of alternative investment funds (AIFs) and the undertakings for collective investment in securities funds (UCITS) that manage them. As of January 11, 2021, companies will be responsible for reporting for their SMALLCs, which do not have the resources to have a regulatory reporting function. Emir Refit was created to reduce the burden of bilateral reporting on non-financial counterparties that are below the clearing thresholds (NTPs). From 18 June, the responsibility passes to its financial counterpart instead of an NFC notification from its OTC trading page. “The Master Regulatory Reporting Agreement (MRRA) has used the initial isda/FIA reporting agreement as a starting point and extended it to cover the new mandatory reporting obligations under Emir as well as the new reporting obligations under SFTR. The MRRA is structured in such a way that users can choose the provisions relevant to their business relationship,” says Bayley. There is a divergence between associations and market participants regarding the use of a Master Regulatory Reporting Agreement (MRRA) to report on the European Market Infrastructure Regulation (Emir) and the Securities Transaction Regulation (SFTR). “It`s a way to document [delegated reporting agreements] in a standard format, so you don`t need to recreate new documents on a bilateral basis and there`s no huge legal effort in drafting, but it goes backwards and is pretty close to the criteria of the settlement,” Talks says. The Association of Financial Markets in Europe (AFME), Futures Industry Association (FIA), International Capital Market Association (ICMA), International Swaps and Derivatives Association, Inc. (ISDA) and the International Securities Lending Association (ISLA) have published a new agreement to facilitate the communication of the different regulatory systems of the European Union.

But the adviser says delegated reporting agreements are usually between two and four pages. Some say that the standard contract format will facilitate agreements. Others suggest that the document is too complex and time-consuming to be widely disseminated. The reporting requirements for securities financing transactions (FTTs) will be progressively adopted over a period of nine months from 11 April 2020. As in the case of EMIR, the dates from which firms must start reporting securities funding targets vary according to their `type of firm`, with investment firms and credit institutions being the first to comply with the bond targets concluded on or after the maturity of 11 April 20206. Where one counterparty is within the scope and the other is not, the reporting counterparty may be obliged to request information from its counterparty and to require it to waive any confidentiality requirements in order to ensure that it is able to advertise it in relation to the trade repository. While companies may already have agreements with their counterparts for these purposes, the MRRA brings together the group of associations that launched a consultation on this issue on August 14, 2019, with the deadline for submission of returns to August 23. In the feedback document, the associations said they were aware that the timetable for preparing and publishing the agreement was “very difficult”. “If you`re a non-financial company that pays under Emir, you`ve already gone through this testing process and overhead as well as the operational aspect of the resources to support the settlement,” says Catherine Talks, product manager at UnaVista. .

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