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EMIR Trade Reporting Service

EMIR Reporting Obligations

One of the key directives under The European Market Infrastructure Regulation (EMIR) is the obligation to report all derivatives contracts to Trade Repositories (TR), which are entities regulated by EMIR that centrally collects and maintains the records of all derivatives trade related data.

Latest changes to Trade Repository reporting 

On June 9th 2014, NASDAQ OMX Clearing added position reporting for all exchange traded derivatives (ETD) and most OTC contracts. The adding of position reporting facilitates reporting of collateral and mark-to-market values, mandated from August 2014.

Members and counterparties to NASDAQ OMX Clearing are encouraged to also add position reporting, in order to ensure consistent reporting of derivative contracts, in accordance with the EMIR regulation.

Key changes in characteristics of the reporting from June 9th 2014 onwards

  • ETD and standardized OTC trades are only reported in their end of day state, as “N” new
  • ETD and standardized OTC trades in their end of day state are reported as “Z” compressed
  • All trades that have been compressed are then reported as new or modified positions
  • Life cycle events on T+1 or later, for ETD and standardized OTC instruments, are reported as new trades followed by a compression followed by a position update
  • The CCP provide collateral values for counterparties but do not include this in its own report 
  • Daily mark to market values are reported for all active positions and relevant OTC trades
  • Changed position UTI format, all position UTIs include a two-digit expiration year in position 51-52
  • CFI codes for ETD and standardized OTC contracts are included directly in the EMIR Trade report (Common data field 3)
  • Underlying (Common data field 4) are reported as blank (“”) for commodities products
  • Trades previously reported erroneously with zero notional amounts have been corrected

NASDAQ OMX EMIR Trade Reporting Service

NASDAQ OMX provides a service for Nordic Market Participants for MiFID trade reporting (TRS) to local Financial Supervisory Authorities (FSA) and will extend its reporting service to cover EMIR derivative reporting to Trade Repositories.

The NASDAQ OMX EMIR Trade Reporting Service Includes


Establishing connectivity with relevant Trade Repositories

  • Reporting of derivatives contracts traded and cleared on NASDAQ OMX’s markets

  • Reporting of OTC derivatives transactions that are not traded or cleared by NASDAQ OMX

  • Ability for members to append required data to derivatives transactions for reporting

  • Daily updates to the Trade Repository of collateral and mark-to-market valuations

  • Reporting feedback of submitted reports

  • NASDAQ OMX further aims to extend its service to include reporting obligations under REMIT for the energy market. Details on this service will follow later.

Service Interface

The service is provided with a flexible interface where the Customer can select to interact with the service via a provided application or by uploading fixed formatted files.

The service application is a user friendly desktop application that enables the Customer to perform the following activities:

  • View status of submitted reports
  • View status of individual reported transactions
  • Search for historical reports
  • Review and confirm NASDAQ OMX generated reports
  • Create new transactions for reporting
  • Export data to external systems

New transactions may also be uploaded via the application as CSV-files according to preformatted templates.

For more information

For more information on NASDAQ OMX EMIR Trade Reporting Service please contact your Key Account Manager or TradeReporting@nasdaqomx.com.

EMIR Trade Reporting with NASDAQ OMX Clearing as counterpart

For those NASDAQ OMX members that intend to manage the reporting themselves, more information on data collection, API information, UTI methodology, back loading and how NASDAQ OMX is reporting, can be found in the

NASDAQ OMX Clearing uses REGIS-TR for its own TR-reporting

NASDAQ OMX Clearing is registered at CICI Utility and the LEI is: 54930002A8LR1AAUCU78

Example reports including new fields relevant for trade reporting can be found in Related Documents at the top.

Further queries on self trade reporting can be directed to Derivatives.TR@nasdaqomx.com

 

FAQ - Frequently Asked Questions

Outsourcing of trade reporting

Can we outsource our trade reporting to NASDAQ OMX?

Yes, NASDAQ OMX Broker Services provides a service for this – EMIR Trade Reporting Service. Please contact your Key Account Manager or TradeReporting@nasdaqomx.com for information on the service including onboarding and pricing. Additionally, please visit

Details for reporting

Why did the UTI change with position reporting?

The current position UTI format will be amended in order to add two digits (year). This is being done in order to avoid issues with re-occurring instrument series names. The change will be implemented on June 9th 2014.

In order to create consistency and enable possible updates to positions that were back-loaded in February, these positions need to be cancelled and re-entered using the new UTI format. In order to facilitate this effort, NASDAQ OMX Clearing will provide a list of the cancelled and re-entered position reports in the EMIR Trade report.

How to change the UTI format of back-loaded positions?

  • Identify the expiration year for the instrument series (e.g. 2016)
  • Replace the two last digits (position 51-52) of the old position UTI with the two last digits of the expiration year.

Example

  • Old Position UTI: 000CSTO000MEMBRIDACCOUNTIDxINSTRUMENTNAMExxxxxxxxxxx
  • New Position UTI: 000CSTO000MEMBRIDACCOUNTIDxINSTRUMENTNAMExxxxxxxxxYY (where “YY” is the expiration year of the instrument series “INSTRUMENTNAME”)

How does position reporting work?

Please see below for details of how to report after June 9th 2014:

  • NASDAQ OMX Clearing will report positions for ETD and most OTC contracts (excluding interest rate swaps and TM FRAs). All forward contracts will be reported on position level.  
  • New trades will only be reported in their end of day state.
  • A compression event will be reported for each new trade, indicating that the trade has reached its end-of-life state.
  • Updates to a trade on T+1 or later will be reported as new trades updating the existing position.

On the first day of position reporting, i.e. June 9th 2014, a compression event will be sent for each active trade that was previously reported on trade level.

Please see the EMIR handbook for further detailed descriptions. Link to handbook valid from June

When will NASDAQ OMX Clearing start reporting of mark-to-market and collateral values?

NASDAQ OMX Clearing intends to start reporting mark-to-market and collateral values from June 9th 2014, in preparation for the mandatory start date in August.

What derivatives contracts are covered by trade reporting obligations?

All derivatives contracts in all asset classes (equity, interest rate, currency, commodity and credit). However, for the purposes of trade reporting, the following securities in Genium INET are not considered as derivatives and are consequently not covered in NASDAQ OMX's trade reporting:

  • Certified Emissions Reductions
  • Electricity Certificates
  • European Union Allowances
  • European Union Aviation Allowances
  • Repo contracts

Where do I find the information I need to report?

See the Handbook on EMIR reporting on where the data is available in the systems, and example “EMIR Reports” for Clearing Workstation (to be found in Related Documents to the right)

Where can we find the information to report if we don’t have API access?

The Handbook on EMIR reporting explains how to collect data to each field, and “EMIR Reports” from Clearing Workstation are published to enable collection of relevant data. Please see example “EMIR Reports” from Clearing Workstation in Related Documents to the right.

How will NASDAQ OMX handle/report back loading?

An explanation back loading can be found in the Handbook on EMIR reporting

How can we calculate Position UTI for back loading if we do not get the Positions Non Propagated Margin Report?

Some members due to specific account set ups do not receive the positions non propagated margin report, in that case they can use the positions report created end-of-day 2014-02-11 and calculate UTIs according to the Emir Handbook or the formulas in the Excel Sheet

Where do we find relevant UPIs?

The guide NASDAQ OMX Clearing - Preliminary CFI-codes (to be found in Related Documents to the right) provides the CFI codes used, which together with the ISIN codes constitutes the UPIs. 

What is NASDAQ OMX methodology regarding UTIs?

An explanation on how NASDAQ OMX Clearing reports trades can be found in the Handbook on EMIR reporting and the guide Cleared UTI for Fixed Income (to be found in Related Documents to the right)

How does NASDAQ OMX handle life cycle events?

An explanation on how NASDAQ OMX Clearing reports trades can be found in the Handbook on EMIR reporting 

Do we need to report intraday changes to trades? (give ups, re registrations etc.)

According to the ESMA Q&A it is not necessary to report all intraday changes to a trade, however NASDAQ OMX will do so until further notice. Changes to this reporting method will take place and information of this will be distributed through the normal distribution channels.

The interpretation of reporting rules seems to be different at each CCP

The major CCPs in Europe have cooperated via the EACH TR working group, in order to reach industry standards in the cases where the EMIR Technical Standards are open to interpretation. NASDAQ OMX Clearing has been part of this working group and we have based the Handbook on EMIR reporting on the standards that have been agreed.

Your methodology doesn’t match our understanding of ESMA guidelines

NASDAQ OMX Clearing has followed the EMIR technical standards and has participated in the EACH TR Working group to design its TR reporting. All interpretations by NASDAQ OMX Clearing are documented in the Handbook on EMIR reporting. For further queries, please contact Derivatives.TR@nasdaqomx.com

Matching difficulties

We are getting unmatched reports for trades with NASDAQ OMX Clearing as counterpart from the Trade Repository – why?

If you are reporting to a different Trade Repository than NASDAQ OMX is, please contact your Trade Repository for support. NASDAQ OMX Clearing is reporting to REGIS-TR

We are getting mismatched reports from the Trade Repository – why?

Please analyze the information from the Trade Repository. Look into the Handbook on EMIR reporting to ensure data is reported in correct field, or ensure you collect correct data from the API or Clearing Workstation “EMIR Reports”. For further assistance, please contact Derivatives.TR@nasdaqomx.com

UTIs do not match – how come?

An explanation on how NASDAQ OMX Clearing reports trades can be found in the Handbook on EMIR reporting and the guide Cleared UTI for Fixed Income (to be found in Related Documents to the right)

How do we reconcile mismatched reports where NASDAQ OMX is our counterpart?

Please refer to the EMIR Report in Genium INET and our TR Handbook to reconcile mismatched data. For further assistance, please contact derivatives.TR@nasdaqomx.com

How will Strip trades be corrected?

Trades with instrument group type “strip”, where contracts with a maturity of more than one month are stripped and broken down into contracts of one month each, have been reported both as the original contract but also the stripped monthly trades. This will be corrected and from April 28th 2014 only the stripped contracts will be reported, i.e. the original contracts will no longer be reported. This issue only affects Freight, Fuel oil, Seafood and Iron Ore contracts with durations of year, half year and quarter.

NASDAQ OMX Clearing will cancel trade reports previously submitted, for original contracts that have subsequently been stripped, in order to ensure that the correct view is held by the trade repository. Members that have used the EMIR trade report provided by NASDAQ OMX Clearing and also reported both original contracts and stripped contracts, are recommended to also cancel the trade reports for the original contracts. 

Testing

How can we test reporting against NASDAQ OMX?

The changes to the reporting will be available for test in the Genium INET Test System 4 (EXT4) from May 14th 2014.

Please contact Member Services for queries regarding access and login IDs. MS.GeniumINET@nasdaqomx.com or +46 8405 6660.

For technical support please contact technicalsupport@nasdaqomx.com or +46 8405 6750.

LEI

What is NASDAQ OMX Clearing’s LEI?

NASDAQ OMX Clearing is registered at CICI Utility and the LEI is: 54930002A8LR1AAUCU78

Do we need to have a LEI?

All counterparties that are required to submit TR reports must have an LEI and report its LEI to NASDAQ OMX Clearing.

In cases where we do not have a LEI for our counterpart, we will use the NASDAQ OMX member participant code to identify our counterpart. Please visit http://www.leiroc.org/

Alerts

In the event of major disturbances to NASDAQ OMX Clearing’s trade reporting – how will we be informed?

In the event of major disturbances to the reporting, NASDAQ OMX will communicate this via the normal Clearing Message channel. Please sign up for this here.

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