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EMIR Trade Reporting Service

EMIR Trade Reporting ServicesNOS Clearing

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.

When does the Trade Reporting Obligation begin?

The start date has been subject to the authorization of Trade Repositories, and the November 7th 2013 four Trade repositories were authorized. ESMA updated version of EMIR Implementation timeline shows the February 12th 2014 as the start date for trade reporting, for all derivative asset classes and for both ETD and OTC derivatives.

Other relevant dates for reporting are:

  • Back reporting of derivative contracts outstanding on August 16th 2012 (and still outstanding on reporting start date) – within 90 days of the reporting start date for that asset class

  • Back reporting of derivatives entered into before, on, or after August 16th 2012 that are no longer outstanding on reporting start date – reportable within three years of the reporting start date for that particular asset class

Who is affected?

  • All counterparties to all derivative transactions

  • Includes financial and non-financial counterparties

  • Under EMIR, a counterparty outside the EU does not have to report to a Trade Repository

How does Trade Reporting affect you?

Trade Reporting covers all derivatives contracts

  • Equity, interest rate, currency, commodity and credit
  • Includes OTC (including those that are not centrally cleared) and exchange traded derivatives
  • Differs from Dodd Frank by including exchange traded derivatives
  • No exemptions for “non-EEA derivatives”
  • Trading venue and underlying assets are irrelevant

There is no threshold below which derivatives contracts are not reportable

Trade Reporting includes modifications to the economic criteria of the trade such as:

  • Novation
  • Modification
  • Changes of valuation or collateralization
  • Terminations and partial terminations

Trade Repositories will receive derivative trade details from different sources and make the information available to all relevant regulators.

NASDAQ OMX EMIR Trade Reporting Service

NASDAQ OMX already 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 will conduct its own reporting to REGIS-TR

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

All members have been requested to report its LEI to LEI@nasdaqomx.com. Should the LEI still be missing by start of reporting, NASDAQ OMX will use the member’s participant ID to populate this field. 

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

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

Testing

How can we test reporting against NASDAQ OMX?

External Test system 1 (EXT1) is available for testing of trade reporting information, including connectivity to REGIS-TR’s testing system. Contact MS.GeniumINET@nasdaqomx.com for assistance

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 via this form to LEI@nasdaqomx.com.

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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