FCA clarifies the expectation for investment firms and trading venues ahead of LIBOR transition
We have had a number of clients reach out to us recently on this topic and we are now able to refer them to this FCA notice. UnaVista recommends that clients read the details within the FCA’s notice and confirm the impact on their reporting processes but the question; “should a transaction report be submitted when the reference rate for a previously reported contract changes from LIBOR to an alternative rate (whether as a result of the application of a fallback or otherwise)?”
Is answered clearly by FCA :-
- Where the only amendment to the contract is the reference rate and associated spread, a new transaction report should not be submitted.
- Where other amendments are made to the contract that result in a reportable transaction, such as a change in notional, a new transaction report should be submitted in accordance with applicable requirements.
FCA also clarifies the expected outcomes for trading venues reporting under RTS 23 as onshored and also provides details for firms reporting under UK MIR. Read more UK MiFIR data reporting and LIBOR transition | FCA and UK EMIR news | FCA.
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