In a European Securities and Markets Authority (“ESMA”) press release dated 7 November 2013, the pan-European regulator announced that it had approved the first trade repositories. Trade repositories are firms that collect and maintain the records of derivatives contracts. The registrations will take effect on 14 November 2013, with the reporting obligation beginning 90 calendar days after the official registration date on 12 February 2014. The obligation to report impacts all EU counterparties, counterparties trading with an EU counterparty and central counterparties. Therefore, all alternative investment funds (e.g., US, Cayman or EU) managed by US or EU alternative investment managers will have an obligation to report if they trade with an EU counterparty.

Click here to read more about the approved trade repositories and reporting obligations.