Version date: 1 November 2017 - onwards
TR Question 26: Reporting to TRs: Complex Contracts
Article 9 of EMIR - Reporting to TRs: Complex Contracts
How the following cases should be reported:
a) A contract stemming from another contract (e.g. option on a future)
b) A transaction with 2 legs
TR Answer 26
a) If the first contract ceases to exist before giving rise to the second one which is materially different from the first one, the two contracts should be reported separately. Therefore, even though the two contracts are connected in the way they come into existence, they should be reported in two separate reports.
b) Both legs of the contract should be reported in one report, where the combination of fields in the Annex of the Commission Delegated Regulation (EU) No 148/2013 (RTS on reporting to TR) provides for this. Otherwise, a report per leg should be submitted.