Trade Repositories
The Trade Repositories (TRs) are licensed companies that centrally collect and maintain the records of derivatives. Once registered, the TR is supervised by ESMA in order to ensure that it complies on an on-going basis with all EMIR requirements, thereby enabling regulators to access to data and details of derivative contracts in order for them to fulfil their respective missions. The companies can choose one of the TRs to which the trades will be reported on a daily basis. One company can use more than one TR for reporting their trades, however this is not cost effective approach. The following trade repositories have been registered by ESMA:
| Trade Repository | Derivative asset class | Currency of the fee structure | Effective date |
|---|---|---|---|
| DTCC Derivatives Repository Ltd. (DDRL) | All asset classes | UK, fees in USD | 14/11/2013 |
| Krajowy Depozyt Papierów Wartosciowych S.A (KDPW) | All asset classes | Poland, fees in PLN | 14/11/2013 |
| Regis-TR S.A. | All asset classes | Luxembour g, fees in EUR | 14/11/2013 |
| UnaVista Ltd. | All asset classes | UK, fees in GBP | 14/11/2013 |
| CME Trade Repository Ltd. (CME TR) | All asset classes | UK, fees in GBP | 05/12/2013 |
| ICE Trade Vault Europe Ltd.(ICE TVEL) | Commodities, credit, equities, interest rates. FX (since 4 June 2015) | 05/12/2013 | |
| Bloomberg Trade Repository Limited | Commodities, credit, foreign exchange, equities and interest rates | UK, fees in GBP | 07/06/2017 |
| NEX Abide Trade Repository AB | Commodities, credit, foreign exchange, equities and interest rates | UK, fees in GBP | 24/11/2017 |
Every TR has a different fee structure that consist of the following elements:
- Fee per annum;
- Fees per trade on the basis of the number of the reported trades with different lower bands and upper bands;
- Max caps, i.e. maximum fees on the basis of the number of the reported trades;
- Maintenance fee is applied by some of the TRs;
- Additional consultancy fees are applied only by one of the TRs.
Apart from the fact that the different TRs have different currencies for their fee structure (as shown in the table above) the TRs have a different fee policy regarding a trade reported only by one side (i.e. reported only by one of the counterparties), or trade reported by both sides simultaneously. In other words some TRs are more cost effective when it comes to reporting per UTI (unique trade identifier). Other TRs have additional fees for large clients reporting large number of trades per day.
On 11 January 2018 ESMA has published a Thematic Report on the fees charged by Credit Rating Agencies and Trade Repositories. One of the concerns are the fee caps (maximum fees charged by the TRs). This will result in increase of the fee caps and/or establishing additional fees on top of the fee caps by the TRs. The clients of the delegated EMIR reporting providers will be largely affected as those additional costs will be transferred to the final client. More information about the Thematic Report is available here.
As all fees impose a substantial financial burden to the reporting entities. For that reason it is very important for the company to choose the best TR in the context of the EMIR reporting. The contracts with the TRs are covering one year period.
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