CME reporting closure FAQs

May 29, 2020

CME have today released their FAQs on the termination of their transaction reporting services, and updated their rulebook to include a chapter on the closure of their repositories (see chapter 10).

Control Now would like to highlight that complete and accurate reporting remains the responsibility of the reporting firm during the closure of the CME service and transition to another service provider. With this in mind, and based on the below comments from the CME, we highly recommend reporting firms complete the following;

  • Correct all historical errors with the CME ASAP.
  • Port to a new TR ASAP.
  • Request an extract from the CME after porting for all data which they have ported.

When this is completed, reporting firms will be able to maintain a full audit trail for reporting in the case of future regulatory inspection.

If firms require support with remediation and porting, please contact .

 

Please see below for a summary of the CME notifications;

Ref Subject Description Cross reference
1 Backstop Porting Date All requests for porting must be completed by 15th November 2020.  FAQ: Q24
2 Backstop Porting Where a reporting firm has not submitted and agreed a porting request with the CME by the backstop porting date, the CME will complete porting to a trade repository of their choice;

“CME ETR shall be authorised to transfer the remaining Derivative Data of any User or Delegated Reporting Service Provider or former User to one or more EMIR trade repository or trade repositories selected by CME ETR in its absolute discretion”

ETR Rulebook: Chapter 10
3 Deletion of data Following porting, the CME no longer provide TR services to the investment firm and will delete all data from their database and no longer support reporting firms with any queries.

“CME ETR shall be authorised to delete such Derivative Data in accordance with the requirements of EMIR and ESMA and CME ETR shall not provide access to such Derivative Data to any person following such deletion.”

ETR Rulebook: Chapter 10
4 No legal liability The CME will not assume any responsibility for issues with porting following completion of the exercise;

“CME ETR shall have no liability or responsibility for the actions or omissions of any New TR in relation to Voluntary Withdrawal Event Porting or Backstop Porting”

ETR Rulebook: Chapter 10
5 Scope All CME repositories outside north America are being closed. FAQ: Q2
6 Data requests If you wish for a drop copy of your data submitted to the CME, this must be completed by 30th September 2020 FAQ: Q7
7 Hard closure date The CME will stop accepting data into their database on the 13th November 2020 FAQ: Q9
8 ASIC clients porting For reporting firms using the CME for ASIC reporting, it is the responsibility of the reporting firms to manage the porting or data to another ASIC repository. FAQ: Q10
9 Porting dates CME will complete porting on a first come first serve basis FAQ: Q13
10 Outstanding Errors If outstanding errors are not corrected, they will not be ported FAQ: Q14
11 Contract Termination The CME are accepting requests to terminate their contracts prior to the 30th November 2020. FAQ: Q29