REMIT Reporting Services and Solutions - July 2015 updated March 2016
6.5 Combining solutions
In many cases, adopting one solution type may be too simplistic an approach to meeting the regulatory
requirements. Instead a combination of solutions may be more optimal. The combination could be temporary or
permanent.
6.5.1
Temporary combinations
The most obvious temporary solution is one that lasts for REMIT phase 1, and is then replaced for phase 2. For
example, it may be optimal for phase 1 to sign direct agreements with OMPs, but to then plan to use standalone
software for phase 2, not only for off venue trades but for all trades. This has the benefit of allowing more time for a
solution to be implemented, whilst phase 1 is “taken care of”. OMP trades can be reported from 7th October by the
OMP and the focus can be on reporting off venue trades using the software by 7th April. After that date, OMP trades
can also be brought into the system when ready, even if the OMP does the actual reporting to reduce liability. The
data can then be used so that a full record of all activity is kept.
This approach works best when the OMPs are exchanges, since the post trade event issue does not need to be
handled. The approach could also utilise a service on a temporary basis, if the service is easy to implement.
6.5.2
Using a combination of OMP reporting and uploading
In some cases, it may be feasible to use each OMP’s service to report on venue orders and trades, but to load off
venue trades to a separate RRM. It is likely that this combination will be used by many, especially by smaller market
participants who only trade on a few OMPs and do not have a high volume of off venue trades, which is a common
scenario. Where the OMP offers a “full RRM” service, the combination will involve using the same provider. Given
the later ruling on liability, this option may now prove to be more popular.
Variations of this combination are also possible. For example, a service could be used for OMP trades alongside an
upload to elsewhere.
6.5.3
Using a TR/RRM
Some EMIR Trade Repositories (TR) also offer a “full” RRM service, thus turning them into a “one stop shop” for
regulatory data reporting. When considering holistic requirements for reporting, including EMIR and others, there
are benefits in selecting such a destination, as outlined in section 4.9.2.
Copyright 2016 – ETR Advisory Ltd and Commodity Technology Advisory LLC
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