We are entering the homestretch before the EMIR REFIT goes live on April 29th 2024. During Q4, ESMA released the 'Guidelines for Reporting Under EMIR'. There weren't any dramatic updates to the paper as it closely followed ESMA's decisions they had published in December 2022's final report.

Elsewhere, the DTCC announced that their UAT environment for EMIR REFIT testing went live in December. The UAT launch followed similar setups earlier this year from REGIS TR and Unavista. With the UAT environments available and EMIR Guidelines out, we have moved from the preparation to testing stages of the REFIT.

From Preparation to Testing

Since April 2022, Cappitech has published a number of preparation blogs. Among them was a blog on key points to consider when firms are creating a preparation strategy for the REFIT. With less than four months to go for the REFIT it's time to shift the focus on feedback of challenges of preparing data for testing.

Many of the topics were covered in the EMIR section of Cappitech's End of the Year Regulation webinar.

• Lifecycle event capture: The REFIT adds a new complexity of Event Types that need to be entered. What we have found is that most firms are encountering challenges with capturing nonregular events such as Corporate Events and Novations. For many companies, we put in place a process to easily handle the default lifecycle events that cover 99% of trades with non-default events being able to be processed through override comments in source data.
• Counterparty 2 data collection: During the webinar a poll was asked to gauge if firms were experiencing challenges with collecting new data needed for counterparty 2 fields. 76% of respondents answered that they were having difficulties. As these are mandatory fields, it shows the importance of putting a dedicated effort to collect this information earlier than later.
• UPI Enrichment: During our November Customer Working Group and speaking directly to customers, one of the areas of feedback is that many firms are struggling to fully define what account type they need for UPIs at ANNA DSB and the full scope of different UPIs they will need. To solve this question, firms need to answer these questions; are UPIs for T+0 reporting needed? Are they creating UPIs? How many unique UPIs do they have and whether an API is needed for UPI lookup?

S&P Global provides industry-leading data, software and technology platforms and managed services to tackle some of the most difficult challenges in financial markets. We help our customers better understand complicated markets, reduce risk, operate more efficiently and comply with financial regulation.

This article was published by S&P Global Market Intelligence and not by S&P Global Ratings, which is a separately managed division of S&P Global.