Research European Commodity Market Regulations - Part 1 | Page 15

European Energy Market Regulations V3.1 Clearing Information – Including the Clearer ID and time of clearing. Status – “New/modify/cancel/termination/compression/valuation update/other.” – Each time a trade changes it must be resent with a new status. In addition to the above, FCs and NFC+s must report collateral and valuation information on a daily basis. However, this reporting will only start 6-months after the initial reporting. Some details of this data are examined in the “realities of implementation” section below. When should data be reported? Data typically should be reported to a repository by the end of the next working day. This includes when some of the data, such as the confirmation data, is missing. It should be sent later in an update. Trades executed after 4pm count as the next day’s trades in terms of measuring T+1. Backloading EMIR came into force on 16th August 2012. This means that any data on trades in existence then must also be reported or “backloaded” to repositories. By implication, it is important to locate this data as soon as possible. Backloading is required in several stages: Trades still open on the first reporting date (i.e. February 12th 2014) – 3 months later (i.e. May 12th 2014) Trades executed after August 16th 2012 but that matured before the first reporting date- 3 years after reporting date Trade executed before August 16th 2012 but that were still open on 16th August 2012 – 3 years after reporting. Trade Reporting for REMIT Which data must be reported? REMIT reporting falls into the following two categories at the highest level: • • Trade Data – Data related to trades and orders Fundamental Data – Data related to the physical state of the grid, e.g. outages, loads, etc. Here we focus on trade data. REMIT covers Physical Power, Gas, LNG and Emissions, as well as their related derivatives. Technically, therefore some of the derivatives will fall under both REMIT and EMIR. However, ACER has put forth a principle of the “avoidance of double reporting”. In theory, this means that if you report data under EMIR you do not have to report it again under REMIT. However, since REMIT requires additional data elements to EMIR, it is not yet clear how and if this will work in practice. Where should data be reported to? ACER will be collecting all of the reported data and using it to monitor the market for abuse. A system called “ARIS” (ACER’s Regulatory Information System) is being built for this purpose. Because of the large number of market participants, ACER do not wish for data to be sent to them directly, instead, they need to be sent via intermediaries called “Registered Reporting Mechanisms (RRMs). These third party facilities will each have their own way of collecting the data and forwarding it to ACER. © Commodity Technology Advisory LLC and ETR Advisory Ltd, 2013, All Rights Reserved. v3.1 November 13th, 2013 15