CySEC reviews EMIR data quality

January 12, 2023

CySEC recently carried 40 reviews of data reported to TRs between January 2021 and August 2022 to assess the quality of reported data.

They published their 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 timezones
  • 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”


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