At an industry event in London last month, an executive at one trade repository recalled his conversation with a corporate treasurer in August 2012, after the completion of the European Market Infrastructure Regulation (Emir) set the continent’s derivatives users on the road to mandatory reporting of listed and over-the-counter trades. “What’s the fine for non-compliance?” asked the treasurer, prompting the executive to admit he did not know. “Well, come back to me when it’s greater than the cost of the solution,” the treasurer replied.
A fortnight away from the start of the new regime, attitudes are less cavalier. Big corporates are racing to be ready for the February 12 start date – tagging thousands of existing trades with the unique trade identifier (UTI) that will enable their transactions to be backloaded into one of six authorised repositories, for example, or obtaining the legal entity identifier (LEI) that acts as a name badge for each trading subsidiary
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