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12th January 2023

CySEC Reviews EMIR Data Quality

CySEC recently carried 40 reviews of data reported to TRs between January 2021 and August 2022 to assess the quality of reported data. It published results in circular C545.

Please find a summary of issues observed here;

  • Option contracts were reported as contracts for difference (‘CFDs’)

  • CFD contracts were identified with an ISIN of underlying

  • Wrong asset class

  • Forwards reported as CFDs (and vice versa)

  • Missing terminations

  • Incorrect Collateralisation

  • Operational issues caused by processing in different time zones

  • Outsourced provider system issues

  • Painting and matching issues – UTIs not matching

  • Internal client codes where LEI available

Investment firms have been “urged to regularly review the procedures established, implemented and maintained, in relation to EMIR reporting”.