On 30 September 2021, ISDA submitted a response to the European Securities and Markets Authority’s (ESMA) Consultation Paper on the Guidelines on reporting under EMIR. Two response documents were submitted: one provides responses to the questions put forward by ESMA and the second document provides comments on the validation and reconciliation rules. In the response, ISDA highlighted a several points including:
- The application of field reconciliation and tolerance levels
- The use of UPIs and related reference data
- The format of TR reports
- ETDs being reported as OTC derivatives when executed on third country markets
ESMA intend to publish a final report on the EMIR reporting guidance in the first quarter of 2022 based on the response received for this consultation.
Documents (2) for ISDA Responds to the ESMA Consultation Paper on the Guidelines on Reporting under EMIR
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