Last week, ESMA issued an updated version of the EMIR Questions and Answers document, which can be found here. Two answers were added, which relate to the use of the exemption to the reporting of intra group derivatives transactions that can be applied for under EMIR REFIT (see here). Answer TR51 m provides guidance on whether the exemption can be used where the parent of the group is within a third country, and indicates that in many cases it may not be applied. Answer TR 51 l provides guidance as to how to report when the exemption ceases to apply. The answers are found on page 121.
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Source: CTRM Center