Leo Labeis, CEO at REGnosys, discusses everything that financial institutions need to know about EMIR Refit and how they can prepare with Digital Regulatory Reporting (DRR)

There is now less than a year until the implementation date for the much-anticipated changes to the European Markets Infrastructure Regulation (EMIR). The amendments, which are set to go live on 29 April 2024, represent an important landmark in establishing a more globally harmonised approach to trade reporting.

Despite the fast-approaching deadline, concerns are growing around the industry’s preparedness, with a recent survey from Novatus Advisory finding that 40% of UK firms have no plans in place for the changes, for instance.

Much of the focus in 2022 was on implementation efforts for the rewrite of the Commodity Futures Trading Commission’s swaps reporting requirements (CFTC Rewrite), which went live on 5 December. Both the CFTC Rewrite and EMIR Refit are part of the same drive to standardise trade reporting globally. While EMIR Refit was originally anticipated to roll out first, implementation suffered from repeated delays to its technical specifications, in particular the new ISO 20022 format. The ISO 20022 mandate was eventually excluded from the first phase of the CFTC Rewrite, hence the earlier go-live date.

In parallel, the Digital Regulatory Reporting (DRR) programme has emerged as a key driving force in helping firms adapt to continually evolving reporting requirements. Having participated in the DRR build-up for their CFTC Rewrite preparations, how can firms leverage these efforts to comply with EMIR Refit in 2024?

The drive to standardise post-trade

Leo Labeis

To understand the new EMIR requirements, it is important to first look at the two main pillars in the global push to greater reporting harmonisation.

The first is the Committee on Payments & Market Infrastructures and International Organization of Securities Commission’s (CPMI-IOSCO) Critical Data Elements (CDE), which were first published in 2018 to work alongside other common standards including the Unique Product Identifier (UPI) and Unique Trade Identifier (UTI). These provide harmonised definitions of data elements for authorities to use when monitoring over the counter (OTC) derivative transactions, allowing for improved transparency on the contents of the transaction and greater scope for the interchange of data across jurisdictions.

The second is the mandating of ISO 20022 as the internationally recognised format for reporting transaction data. Historically, trade repositories required firms to submit data in a specific format that they determined, before applying their own data transformation for consumption by the regulators. The adoption of ISO 20022 under the new EMIR requirements changes that process by shifting the responsibility from trade repositories to the reporting firm, with the aim of enhancing data quality and consistency by reducing the need for data processing.

Preparing for the new requirements with DRR

DRR is an industry-wide initiative to enable firms to interpret and implement reporting rules consistently and cost-effectively. Under the current process, reporting firms create their own reporting solution, inevitably resulting in inconsistencies and duplication of costs. DRR changes this by allowing market participants to work together to develop a standardised interpretation of the regulation and store it in a digital, openly accessible format.

Importantly, firms which are using the rewritten CFTC rules which have been encoded in DRR will not have to build EMIR Refit from scratch. ISDA estimates that 70% of the requirements are identical across both regulations, meaning firms can leverage their work in each area and adopt a truly global strategy. DRR has already developed a library of CDE rules for the CFTC Rewrite, which can be directly re-applied to EMIR Refit. Even when those rules are applied differently between regimes, the jurisdiction-specific requirements can be encoded as variations on top of the existing CDE rule rather than in silo.

Notably the UPI, having been excluded from the first phase of the CFTC Rewrite roll-out, is mandated for the second phase due in January 2024. DRR will integrate this requirement, as well as others such as ISO 20022, and develop a common solution that can be applied across the CFTC Rewrite and EMIR Refit.

As firms begin their own build, the industry should work together in reviewing, testing and implementing the DRR model. Maintaining the commitment of all DRR participants will strengthen the community-driven approach to building this reporting ‘best practice’ and serve as a template for future collaborative efforts.

Planning for the long-term 

Although the recent CFTC Rewrite and next year’s EMIR Refit are centre of focus for many firms, several more G20 regulatory reporting reforms are expected over the next few years. These include rewrites to the Australian Securities and Investments Commission (ASIC), Monetary Authority of Singapore (MAS) and Hong Kong Monetary Authority (HKMA) derivatives reporting regimes, amongst others.

Firms should therefore plan for the entire global regulatory reform agenda rather than prepare for each reform separately. Every dollar invested in reporting and data management will go further precisely because it is going to be spread across jurisdictions, easing budget constraints.

Looking ahead, financial institutions should establish a broad and long-term plan is to learn from their CFTC Rewrite preparation and how DRR can be positioned in their implementation. For example, firms should ask themselves which approach to testing and implementing DRR works best: via their own internal systems or through a third-party? Firms should review what worked well in their CFTC Rewrite implementation and apply successful methods to EMIR Refit. Doing so will enable firms to have a strong foundation for future updates in the years to come.

Ian is the CMO at Spotler Group

Seth Godin, a writer, speaker, marketing expert, and influencer, describes audiences as tribes, which are groups of people with shared beliefs. As a startup or founder, it’s important to determine who your product or service is for and how to connect with them. This is what Seth Godin refers to as finding your tribe.

Content marketing serves as a means to establish this connection. It involves consistently providing valuable content that attracts people who identify with your tribe. While paid search and ads can be part of your strategy, building an audience that you own will yield long-term benefits. But where should you begin?

Firstly, you need to think like a media business or publisher. The goal of your marketing strategy should not solely be to sell more products but to identify and cultivate an engaged audience that trusts you and eventually becomes your customer. Your goals should not be driven by popularity contests but by what success looks like for your content. It’s important to understand that your content won’t appeal to everyone, so determining your minimum viable audience is crucial. Casting too wide a net may result in content that lacks specificity.

When identifying your audience, consider not only your buyers but also influencers in your industry and individuals within target organizations who can influence your buyers internally. Understand their needs, pain points, and personal goals. Recognize that personal risk, or the fear of failure, strongly influences buying behavior.

Ian

The needs of your audience may be related to or tangential to your product or service. For example, if your product is sold to government entities and requires an understanding of government procurement, providing assistance in that area can address their most urgent need. Additionally, if your product or service requires education, you must inform your audience about the problem it solves and how it can be resolved. Remember that you’re not only competing with similar vendors but with all the information available on the internet related to your industry or category.

To stand out, you must give your target audience a reason to choose your community and content over others. Offer unique research, insights, customer case studies, or a differentiated point of view. Focus on a niche within a broader category or topic that is currently underserved. Although it may seem counterintuitive, catering to a smaller niche can help you establish trust and expand your audience over time.

When it comes to building your content marketing strategy, avoid the temptation to be present on all channels at once. Validate whether your audience is present on a particular channel and consumes the type of content you plan to produce. Instead, focus on a medium and channel where you can excel before expanding. Be deliberate in driving your audience to an owned media property, such as a mailing list, rather than relying solely on social media platforms.

Consistency, predictability, and reliability are key to whichever platform and medium you choose. It takes time for people to become aware of your presence and locate your valuable content. Whether it’s a weekly LinkedIn newsletter or a monthly podcast, remain committed to your chosen channel.

As a content publisher, you’ll need to market your content marketing. Simply building it and expecting an audience to come is no longer sufficient. While organically building an audience is increasingly difficult due to the noise and social media algorithms favouring paid models, you can still engage with key members of your intended audience through social media. Build a target list, follow them, share and like their content, and establish trust and awareness within that core group. Gain insights into what your audience needs.

At some point, you may need to incorporate paid promotion into your strategy to accelerate audience growth. Use the insights you’ve gained about your audience’s preferences and needs to target your ad spend effectively. Above all, be generous and useful in your content sharing, focusing on providing value rather than selling.

Lastly, continually assess and track the effectiveness of your strategy. Your audience will provide feedback and engagement metrics will indicate whether your content resonates with them. Adjust your approach as needed based on this feedback.

By following these principles and focusing on building and engaging with your tribe, you can establish a loyal audience that trusts your content and ultimately converts into customers.

Ian Truscott

Ian is the CMO at Spotler Group, a trusted executive advisor and mentor, and the host of the Rockstar CMO podcast. Ian deeply understands the process of taking B2B technology to market, having started his career as a technologist before holding leadership positions in product development, management and marketing before holding the top marketing job. Aside from his leadership positions with successful technology vendors, his rounded marketing experience and insight comes from strategic client consulting with agencies, his own practice and as an industry analyst working with clients that included American Express, Nasdaq, Jaguar LandRover, General Motors and several leading B2B technology vendors. Ian believes the role of marketing is to create ART, awareness, revenue and trust, and he can often be found writing on this topic and speaking at events and on podcasts.