Frances Faulds
Frances Faulds

Transaction Reporting of OTC FX Derivatives - what are your options?

With the EU’s European Market Infrastructure Regulation (EMIR) requiring institutions to report their OTC derivatives trades to appropriate trade repositories starting as early as September 2013, Frances Faulds talks to REGIS-TR and Traiana to assess the options available to FX firms under both the Dodd-Frank Act (DFA) and EMIR.

With the new trade reporting obligations finalised, the countdown to this major new regulatory requirement for the FX market has begun bringing on the one hand certainty to FX firms, but on the other, a limited number of options due to the time constraints for those firms just starting preparations. The good news is that solutions are available and that much of this work can be outsourced or help is at hand for those firms making a strategic decision to report trades directly. The major distinction between reporting under Dodd-Frank and EMIR is that under Dodd-Frank the reporting obligation is ‘one-sided’ while under EMIR it is ‘two-sided’.  In practice this means that, more often than not, the reporting participant under DFA will be a financial institution and/or major swap dealer or major swap participant. Under EMIR both counterparts to a derivative transaction have an obligation to report, with the exception of private individuals. The reporting obligation can however, be...continued

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