„[Reporting agreements] highlight the risks and the risks remain to the counterparty that has a reporting obligation, not to the company that provides delegated reporting,“ the advisor explains. „It`s pretty simple.“ This new agreement applies to the EMIR Regulation, but it also applies to the Securities Financing Transactions Regulation (SFTR), the first phase of which is expected to come into force in April 2020. The Master Regulatory Reporting Agreement (MRRA) is based on the draft similar agreement of the International Swaps and Derivatives Association (ISDA) for reporting in accordance with the European Market Infrastructure Regulation (EMIR). But the councillor says that delegated report agreements are usually between two and four pages long. The Association of European Financial Markets (AFME), Future Industry Association (FIA), International Capital Market Association (ICMA), International Swaps and Derivatives Association, Inc. (ISDA) and the International Securities Lending Association (ISLA) have published a new agreement to facilitate reporting on various regulatory systems in the European Union. The experienced Dentons team is pleased to assist you with each visit to the MRRA based on your existing reporting agreements. We know that many companies have adapted the existing reporting agreement to their internal needs and we would be happy to bring your agreements in line with the broader reporting functions of the MRRA. According to the consultant, the cost of building new data points and re-enacting existing delegated reporting agreements far outweighs all the benefits of accepting the model agreement. While Bayley says all necessary technology updates will depend on how existing corporate reporting systems and processes are implemented, UnaVista`s Talks says the development of legal technology solutions to support the deal will depend on the industry adopting the framework. On 14 August 2019, the association group launched a consultation on this subject, with the deadline for submitting reactions being 23 August. In the issue of feedback, the associations stated that they were aware that the timetable for preparing and publishing the agreement was „very difficult“.
Bayley says, however, that the agreement was reached in such a way that it covers all regulations. Some say the standard format of the contract will facilitate agreements. Others believe that the document is too complex and too long to be widely adopted.
