This week I have been dusting off the Q&A release from ESMA in September 2018 regarding the reporting of FX Swaps to ensure we have successfully planned for the impending changes. The aforementioned Q&A included reference data and transaction reporting scenarios where an FX Swap is reported as a single stand-alone financial instrument. This Q&A implementation period was six months and to ensure a consistent approach across reporting requirements, ESMA also published a Q&A on FX Swaps reporting under EMIR, which should be implemented 12 months after its publication, as it is more difficult to implement, but the two are harmonised to ensure consistency.
Last week we looked at the recent GFXC note on Disclosures and today we take a deep dive into the accompanying report. As will be seen, it continues the theme of the importance of disclosures.