While Bayley says all necessary technology updates will depend on how existing corporate reporting systems and processes are implemented, UnaVista`s Talks says the development of legal technology solutions to support the deal will depend on the industry adopting the framework. Reporting obligations relating to securities financing transactions will be phased in over a nine-month period starting April 11, 2020. As with the EMIR Regulation, the data from which companies must begin reporting LTS varies according to their “type of entity,” with investment firms and credit institutions the first to comply with or after the APRIL 11, 20206 SDR. Where one counterparty is within the scope and the other is not, the reporting counterparty may be obliged to obtain information from its counterpart and require the abandonment of confidentiality requirements to ensure that it is able to provide the appropriate information to the central repository. Although companies have already entered into agreements with their counterparties for these purposes, MRRA contains the “If you are a non-financial company reporting under Emir, you have already passed this testing process and overload, and the operational aspect of obtaining resources to support regulation,” says Catherine Talks, Product Manager, UnaVista. “If we just stick to the binding regulations, much of this reporting framework becomes obsolete and much more committed to a vision of reconciliation. While you allow a company to report on your behalf, you should cross-reference these reports and make sure you agree with them. The Master Regulatory Reporting Agreement (MRRA) gives market participants the opportunity to use a single model to help them manage regulatory obligations and provide reporting services under the European Market Infrastructure Regulation (EMIR) and the Securities Financing Transactions Regulation (SFTR). MRRA establishes common conditions for the mandatory and delegated reporting of derivatives transactions under Operation EMIR, consistent with the amendments introduced by EMIR Refit and securities financing transactions under the SFTR. The agreement was also drawn up to ensure that these conditions remain effective after Brexit.
“The Master Regulatory Reporting Agreement (MRRA) used isda/FIA`s initial delegate report agreement as a starting point and extended it to cover the emirs` new mandatory reporting obligations and new reporting obligations under the SFTR. The MRRA is structured to allow users to choose the rules that are relevant to their business relationships,” says Bayley. Some say the standard format of the contract will facilitate agreements. Others believe that the document is too complex and too long to be widely adopted. According to the consultant, the cost of building new data points and re-enacting existing delegated reporting agreements far outweighs all the benefits of accepting the model agreement.