The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the European Commission (EC) requesting a postponement of the European Market Infrastructure Regulation (EMIR) reporting obligation application to the buy-side, Article 9 of Regulation (EU) No. 648/2012.

SIFMA AMG has substantial reservations about the operational feasibility for buy-side market participants of complying with the Reporting Obligation’s current timeframe. They share concerns that applying the Reporting Obligations to buy-side participants before they have had sufficient time to prepare may result in inaccurate reporting, which would militate against the policy goal of regulators achieving a clear overview of the derivatives market. SIFMA AMG details a number of reasons that support a postponement of application of the Reporting Obligation to the buy-side.