ALFI responds to ESMA consultation paper “Guidelines for reporting under Articles 4 and 12 SFTR"

30 Jul 2019 | Statements and Position Papers  

On 26 July, ALFI submitted to ESMA its response to the consultation paper “Guidelines for reporting under Articles 4 and 12 SFTR”.

In order not to reproduce the EMIR experience with an important and still evolving Q&A document, ESMA plans to issue implementation guidelines in Q4-19 ahead of the application in 2020.

These guidelines will both cover the booking principles of SFTs as well as the corresponding reporting principles.

ALFI has been invited to the industry workshop organised by ESMA on 16 July in order to calibrate these guidelines. This was also the opportunity to define/confirm a few booking best practices, applicable in the SFTR regime. These aspects are reflected in the consultation, in particular:

  1. Possibility to allocate a LEI to a pool of assets and to trade at this level (see Q2)
  2. Possibility that ESMA clarifies the application of the guidelines 2014/937, art 43 re. the limitation of re-use for collateral received (see Q79-80). The industry has asked for the possibility to repo the securities received as collateral.

Any guidance provided by ESMA will also reflected in the ALFI guidelines on SFTR, which are currently being drafted. Read ALFI's response.