SFTR: THE ROAD TO TRANSPARENCY
While most asset managers have begun preparations for these requirements, SFTR’s most signi cant and complex phase begins with the implementation of Article 4. Expected to occur in Q1 2018, this phase introduces the mandatory reporting of individual SFTs. The European Securities and Markets Authority (ESMA) is scheduled to release its nal technical speci cations in Q1 of this year. The industry will have one year from this date to comply, making March 2018 the probable start date.
Principals to SFTs must engage in 2017 to develop solutions for satisfying these complex ling require- ments. Firms committed to satisfying them will need to conduct the classic build, buy, or outsource assess- ment. A year may appear to be enough time to nalize solutions but lessons learned from EMIR suggest oth- erwise. It would be foolish to underestimate the tech- nical and stakeholder coordination challenges inherent in satisfying a detailed, dual-sided, reporting regime such as SFTR.
Published in BBH’s 2017 Regulatory Field Guide, available here.