Article: “What a year: MiFID II/MiFIR, EMIR RTS, SFTR and SEC SBS”

The most recent edition of the Journal of Securities Operations & Custody (Volume 9 Number 4) features an article by Lloyd Altman entitled “What a year: MiFID II/MiFIR, EMIR RTS, SFTR and SEC SBS”.  Opening by paraphrasing Heraclitus, “Change is the only constant”, the article focuses on Europe and the US, going into detail regarding all of […]

The OTC Space Logo

EMIR, MIFIR, and SFTR – article by Alan McIntyre in “Rocket 9”

2017 is shaping up as the year of regulatory compliance in Europe. Alan McIntyre’s article “Navigating The Waters of EMIR, MIFIR, and SFTR” in the recent edition of Rocket 9 from The OTC Space  lays out the technical and planning challenges, scope, and overlap between each of the three regimes. In addition to illuminating issues like ESMA’s decision […]


Transaction Reporting and ISO 22

by Alan McIntyre I’m doing the industrious people at the International Organization for Standardization a disservice as it’s really ISO 20022. But ISO 22 is catchier and requires far less effort than ISO Twenty Thousand and Twenty Two. And let’s face it, if we need to get our heads around yet another machine readable language […]


5 Key Takeaways from the CPMI-IOSCO “Harmonisation of critical OTC derivatives data elements (other than UTI and UPI)” – second batch

by Alan McIntyre In October 2016, CPMI-IOSCO published their Harmonisation of critical OTC derivative data elements (other than UTI and UPI) – second batch  Here are our 5 Key Takeaways: Is ISO 20022 the standard? Risk Focus are enthusiasts regarding the benefits that a clearly defined data schema such as ISO 20022 can bring to improve […]

EMIR Article 9 RTS Re-Write – Now What?

By Alan McIntyre and Andy Green                 Has the European Commission fired the starting gun for revised EMIR Reporting RTS, or merely cocked the starting pistol? Almost a year ago, in November 2015, ESMA submitted the revised Regulatory Technical Standard (RTS) and Implementation Technical Standard (ITS) for Article […]


SFTR Shorts, Part 4 – Country Codes for Identifying Location of Branches

This is the fourth and last installment in Alan McIntyre’s informative and well-received “SFTR Shorts” series. The latest consultation paper has a lengthy section around the proposal to use the ISO Country code to identify the location of branches. The alternative would be to use the LEIs of the actual branches, as per the ongoing […]


SFTR Shorts, Part 3 – Is ISO 20022 Still Being Mandated?

The Third in the “SFTR Shorts” Series by Alan McIntyre The short answer to the question in the title is “Very much so”. ESMA is determined to increase the quality and usefulness of reported data by baking-in a strictly controlled ISO 20022 schema from the outset: A common XML schema enables also to embed basic data quality validations […]

ESMA Guidelines

MiFID II – 5 Key Takeaways from the ESMA Final Report

By Dan Tate, Client Engagement Lead,  Risk Focus London ESMA has published their MiFID II Final Report as a result of their Consultation Paper. It consists of updates and changes to the 289 page ‘Guidelines’ which provides the industry with, amongst other things, examples and details on how to populate transaction reporting fields in certain […]


SFTR Shorts, Part 2 – Why is EMIR mentioned and what’s changing under EMIR?

The Second in the “SFTR Shorts” series By Alan McIntyre In order to reduce the cost and burden on the industry, ESMA is mandated to minimize overlaps and avoid inconsistencies between the technical standards implemented for SFTR and EMIR. Accordingly, for pragmatic reasons they look to utilize, or at least provide the opportunity to utilize, as much of the existing […]


So what is this latest SFTR paper that ESMA have published?

The First in a series “SFTR Shorts” By Alan McIntyre In March this year ESMA published a Discussion Paper (ESMA/2016/356) ‘Draft RTS and ITS under SFTR’. In ESMAs words this Discussion Paper was: published as part of ESMA’s consultations on Level 2 measures under the Securities Financing Transactions Regulation. Within the European regulatory framework Level […]