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Master Regulatory Reporting Agreement (Mrra)

In the event that the new regulatory reporting obligations apply to you, you should think about how you want to proceed. This includes the provision: As mentioned in the webinar, isda and other professional associations had written to ESMA seeking regulatory leniency regarding the start of mandatory reporting by financial counterparties for NFC-s on June 18. The webinar was recorded prior to ESMA`s response. While Bayley says any necessary technology updates will depend on how companies` existing reporting systems and processes are set up, UnaVista`s Talks says the development of legal technology solutions to support the deal will depend on industry adoption of the framework. The new reporting requirements will apply from 18 June 2020. In response to a letter from various interbranch organisations calling for a leniency period after the deadline for EMIR Refit reporting obligations of 18 June 2020, the European Securities and Markets Authority (ESMA) stated that “the removal of paternalism from supervisory measures with regard to the provisions in question is not an appropriate way forward” and therefore no leniency period has been granted. Market participants must therefore continue their implementation efforts and work until the current deadline of June 2020. While you may have already entered into delegated reporting agreements with your counterparties, your delegated reporting agreement does not comply with the new regulatory reporting requirements if you enter into OTC derivatives transactions with NFCs below the relevant clearing threshold for all asset classes as of June 18, 2020. The Association of Financial Markets in Europe (AFME), the Futures Industry Association (FIA), the International Capital Market Association (ICMA), the International Swaps and Derivatives Association, Inc. (ISDA) and the International Securities Lending Association (ISLA) have published a new agreement to simplify reporting in various regulatory systems in the European Union. Some say that the standard contract format will facilitate agreements.

Others suggest that the document is too complex and time-consuming to be widely used. In a previous note, we provided a summary of the main changes to the EMIR realignment. The purpose of this note is to provide a brief overview of the new regulatory reporting requirements as part of the emir transformation and to provide guidance on how market participants should prepare for the new requirements. But the consultant says delegated report agreements are usually between two and four pages. Norton Rose Fulbright LLP`s financial services team has extensive experience in all matters related to new regulatory reporting requirements and can help you understand, respond to or create tailored reporting documentation required to meet the new regulatory reporting requirements introduced by EMIR Refit and SFTR or adapt the MRRA. The answer to this question will depend on a number of factors and will not be the same for everyone, but will be largely determined by the CF`s current approach to documentation. For example, in the event that a CF currently has tailored agreements that are part of its terms and conditions, it may be easier to include the new regulatory requirements in the current set of documents. A CF may also wish to review the scope of the contracts and counterparties involved and determine whether or not the CF wishes to offer delegated reporting for TBTs and ETDs in the future. While the existing reporting arrangement dealt with the possibility for a derivatives counterparty to delegate its EMIR reporting obligations, EMIR Refit and sfTR require that if one of the counterparties to the transaction in question is a financial counterparty (FC) and the other party is an NFC4, the FC is responsible and legally responsible for the reporting both for itself and for its counterparty and the accuracy of ensuring the disclosure of information5 (mandatory reporting). The ARMR`s modular approach allows parties to agree on different annexes (and add new ones as regulatory deadlines) to meet their requirements, whether mandatory or delegated.

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