Going through the 174 page consultation document released on May 27, 2019 by the ESMA one cannot help wondering about various solutions that have already been floated by players wanting to be in early on the SFTR game.
Inputs from industry will be reviewed by Q3, 2019 and the final guideline will be released in Q4, 2019. That leaves just a few months before the go-live date on April 12, 2020.
But then, we didn’t see anything in the 174 pages that fundamentally alters the nature of SFTR Reporting – so those few months might be time enough.
(For instance, it is old hat that Field 79 of the table on Loan and Collateral data does not apply to commodities.)
And then there is para 5.11.2 which will have programmers sweating. It is a simple question: when modifying an SFT do you report ALL the data or only the modified data? Choose between Option A or B.
Trying telling a programmer that that is simple!
Now, spotting something like 5.11.2 makes you want to go through the Consultation with a fine tooth comb, lest you miss something dramatic. Or just wait for Q4 and put your shoulder to the wheel to be in time for April 12, 2020.