Frequently Asked Questions

No. Point Nine Data Trust Limited (p9dt.com) is a Cyprus-based regulatory reporting services firm. Point Nine Capital is an unrelated Berlin-based venture capital firm that invests in early-stage SaaS companies. The two share a name and nothing else. #

No. MUFG acquired the former Point Nine Limited's middle- and back-office business in 2019, which now operates as MUFG Investor Services FinTech Limited. Point Nine Data Trust Limited — the regulatory reporting firm at p9dt.com — is a separate, independent Cyprus company (HE 397446, LEI 2138002RMY29Z38WWN81). #

Point Nine Data Trust Limited is headquartered at 148 Athalassas Avenue (5th Floor), Athalassis White Building, 2024 Strovolos, Nicosia, Cyprus. The company is incorporated in the Republic of Cyprus under registration number HE 397446. #

Point Nine Data Trust Limited's Legal Entity Identifier is 2138002RMY29Z38WWN81. The LEI record can be verified in the GLEIF global LEI index. #

All financial counterparties (FCs) and non-financial counterparties (NFCs) established in the EU must report their derivative contracts under EMIR. Both counterparties to a trade are in scope, as are CCPs. Since EMIR Refit, an FC facing a small non-financial counterparty (NFC-) is responsible, and legally liable, for reporting the OTC derivative on behalf of both parties. The same allocation of responsibility applies under UK EMIR for UK-established counterparties. #

Derivative trades must be reported by T+1 — no later than the end of the working day following the conclusion, modification or termination of the contract. This applies to both OTC and exchange-traded derivatives, and to both EU EMIR and UK EMIR. Reports go to a registered trade repository (TR): one registered with ESMA for EU EMIR, or with the FCA for UK EMIR. #

EMIR Refit reporting standards went live on 29 April 2024 in the EU and on 30 September 2024 in the UK. From those dates, all new reports had to use the revised field set and ISO 20022 XML format. Outstanding trades had to be brought up to the new standard within a six-month transition period — by 26 October 2024 in the EU, and by the end of the FCA's equivalent 180-day window in 2025. #

An EMIR Refit trade report contains 203 reportable fields in the EU and 204 in the UK, up from 129 before Refit. The UK's additional field is an optional Execution Agent identifier. Both regimes mandate ISO 20022 XML as the submission format and adopt global CDE (Critical Data Elements), the UTI and the UPI, replacing the previous CSV-based formats. #

Delegated reporting is where one party — typically a broker, bank or third-party service provider — submits EMIR reports to a trade repository on a counterparty's behalf. Delegation is expressly permitted under Article 9 of EMIR. Except where the mandatory FC/NFC- allocation applies, delegation does not transfer legal responsibility: the delegating counterparty remains liable for the timeliness and accuracy of its reports and should supervise the delegate's output. #

Yes — NFCs established in the EU (or UK, under UK EMIR) are in scope of the reporting obligation. For OTC derivatives, an NFC below the clearing thresholds (NFC-) benefits from mandatory allocation: its FC counterparty is responsible and liable for reporting both sides. NFCs above the thresholds (NFC+), NFCs facing other NFCs, and NFCs trading exchange-traded derivatives must ensure their own reports are made, though they may delegate submission. #

A Unique Transaction Identifier (UTI) is a code of up to 52 characters that identifies a single derivative transaction so that both counterparties' reports can be paired at the trade repository. EMIR Refit adopted the global UTI standard and a generation waterfall that determines which party generates it — for example, the CCP for cleared trades, or the FC when facing an NFC. The UTI must be shared in time for both sides to report by T+1. #

Misreporting under EMIR can lead to supervisory action and financial penalties, imposed by national competent authorities in the EU or by the FCA in the UK. Both regimes also expect firms to notify their regulator of significant reporting errors and omissions and to remediate historical misreporting through corrections and, where required, back-reporting. Reconciliation breaks and rejected (NACKed) submissions left unresolved are recurring findings in regulatory data-quality reviews. #

An ARM (Approved Reporting Mechanism) is a firm authorised to submit transaction reports to national competent authorities on behalf of investment firms under MiFIR Article 26. ARMs validate, format and route reports to the correct regulator. In the EU, ARMs are authorised under MiFIR; in the UK, they are authorised by the FCA as data reporting services providers. Using an ARM does not transfer the investment firm's legal responsibility for complete and accurate reporting. #

Investment firms that execute transactions in reportable financial instruments must report those transactions to their national competent authority. The obligation sits with the executing firm, whether trading for clients or on own account. Trading venues must also report transactions executed through their systems by firms not subject to MiFIR. Credit institutions performing investment services are in scope. UK investment firms have the equivalent obligation under UK MiFIR, reporting to the FCA. #

Transaction reports must be submitted as quickly as possible and no later than the close of the working day following the trade (T+1). Reports are made to the firm's national competent authority — directly, through an ARM, or via the trading venue where applicable. Late reporting, over-reporting and under-reporting are all treated as breaches of Article 26. #

A MiFIR transaction report contains 65 fields, defined in RTS 22. They cover the buyer, seller and decision-makers (including natural-person identifiers), the instrument (ISIN), price, quantity, venue, timestamps to the required granularity, and flags such as short-selling and waiver indicators. Identifier accuracy — LEIs for legal entities and national identifiers for natural persons — is one of the most common sources of rejection and regulator queries. #

Reportable instruments are those admitted to trading or traded on an EU trading venue (or for which admission has been requested), plus instruments whose underlying is such an instrument or an index or basket of such instruments — the "TOTV" and "uTOTV" tests in Article 26(2). Firms typically check reportability against ESMA's FIRDS reference database, or FCA FIRDS for UK MiFIR, on the relevant trade date. #

MiFIR transaction reporting is a market-abuse surveillance regime; EMIR is a systemic-risk regime for derivatives. MiFIR reports go to the regulator (via an ARM or directly) in a 65-field format covering all reportable instrument classes, single-sided per executing firm. EMIR reports go to a trade repository, cover derivatives only, are two-sided with reconciliation, and carry 203/204 fields. Many derivative trades are reportable under both regimes simultaneously, with different field content and deadlines. #

Submission can be delegated — most firms report through an ARM, and some rely on their broker or a service provider to prepare and route reports — but legal responsibility cannot. The executing investment firm remains accountable for the accuracy, completeness and timeliness of its transaction reports, and is expected to reconcile its front-office records against samples of the data the regulator actually received, as set out in RTS 22 Article 15. #

UK MiFIR is the onshored version of MiFIR that has applied to UK investment firms since the end of the Brexit transition period on 31 December 2020. The core Article 26 obligation and 65-field RTS 22 format are substantially the same, but reports go to the FCA, reportability is checked against FCA FIRDS rather than ESMA FIRDS, and the two rulebooks and validation rules can diverge over time. Firms in scope of both regimes must report separately to each. #

Counterparties established in the EU — banks, investment firms, funds, insurers, pension schemes, CCPs, CSDs and non-financial companies — must report their securities financing transactions (SFTs) to a registered trade repository under Article 4 of SFTR. The obligation is two-sided: both counterparties report, and the reports are reconciled at the TR. EU branches of third-country firms are also in scope for SFTs they conclude. UK SFTR imposes the equivalent obligation on UK counterparties, with one major exception for NFCs (see below). #

Under EU SFTR, yes — non-financial counterparties are in scope, and if the NFC is small (below at least two of the balance-sheet, turnover and headcount thresholds), its financial counterparty must report on its behalf. Under UK SFTR, no — the UK did not onshore the reporting obligation for NFCs, so UK non-financial companies are exempt from reporting their SFTs, although their in-scope counterparties must still report their own side. #

Four transaction types are reportable: repurchase agreements (repos), securities or commodities lending and borrowing, buy-sell back and sell-buy back transactions, and margin lending in the context of prime brokerage. Collateral reuse, cash reinvestment and margin data are also reportable. Derivatives are not SFTs — they fall under EMIR — although total return swaps sit close to the boundary and are reported under EMIR, not SFTR. #

New SFTs, modifications and terminations must be reported by T+1 — the end of the working day following the event. Collateral that is not known at trade time may be reported by S+1, the day after the value date. Both counterparties must report using a shared UTI, which makes timely UTI generation and exchange one of the main operational challenges of the regime. #

SFTR reporting went live in phases: 13 July 2020 for banks and investment firms (the first two phases combined after a COVID-related delay), 12 October 2020 for insurers, funds and pension schemes, and 11 January 2021 for non-financial counterparties in the EU. The UK onshored the regime at the end of the Brexit transition period, without the NFC phase. #

An SFTR report contains 155 reportable fields across four tables: counterparty data, loan and collateral data, margin data, and reuse data. Reports must be submitted in ISO 20022 XML. Because the regime is dual-sided, a large subset of fields is reconciled between the two counterparties' reports at the trade repository, with tolerance levels defined by ESMA — making inter-party data alignment as important as submission itself. #

Mandatory delegation is the SFTR rule that shifts the reporting obligation for a small NFC onto its financial counterparty. Where an EU NFC does not exceed at least two of the three size thresholds in the Accounting Directive, the FC facing it is responsible and legally liable for reporting both sides of the SFT. This mirrors the FC/NFC- allocation under EMIR Refit. Voluntary delegation to a third party remains available to all other counterparties, without transferring liability. #

SFTR reports must go to a trade repository registered (or recognised) by ESMA for EU SFTR, or by the FCA for UK SFTR. The main repositories offering SFTR services are DTCC's Global Trade Repository and REGIS-TR in the EU, with DTCC's UK entity serving UK SFTR. Firms should confirm current registrations on the ESMA and FCA registers, as the TR landscape has consolidated since go-live. #

Parts 43 and 45 are the two core swap reporting rules under the CFTC's Dodd-Frank regime. Part 43 requires real-time public reporting: price-forming swap data disseminated publicly, as soon as technologically practicable, with time delays for block trades. Part 45 requires regulatory reporting: full creation and continuation data on every swap, reported to a swap data repository (SDR) for CFTC oversight. Part 46 covers historical (pre-enactment and transition) swaps, and Part 49 governs the SDRs themselves. #

CFTC reporting is single-sided: one counterparty per swap reports, determined by a hierarchy. A swap dealer (SD) reports ahead of a major swap participant (MSP); an MSP reports ahead of a non-SD/MSP; and a financial entity reports ahead of a non-financial end user. When both counterparties sit at the same level, they agree which of them is the reporting counterparty. For cleared swaps, the DCO (clearing house) reports the cleared legs. #

The CFTC Rewrite was the amendment of Parts 43, 45, 46 and 49 to align US swap reporting with global CDE standards and to tighten data quality obligations. Phase 1 took effect on 5 December 2022, overhauling the reportable data elements and introducing formal error-correction requirements. Phase 2 took effect on 29 January 2024, mandating the Unique Product Identifier (UPI) for swaps in the credit, rates, FX and equity asset classes. #

Under Part 45, swap dealers, MSPs, SEFs, DCMs and DCOs must report creation data by end of the next business day after execution (T+1); non-SD/MSP reporting counterparties have until the end of the second business day (T+2). Under Part 43, publicly reportable swap transactions must be reported as soon as technologically practicable after execution, with prescribed dissemination delays for block trades and large notional swaps. #

Three SDRs are provisionally registered with the CFTC: DTCC Data Repository (U.S.), ICE Trade Vault, and CME's swap data repository. The reporting counterparty chooses the SDR for each swap; all continuation data for that swap must then flow to the same SDR. SDRs validate submissions against CFTC-mandated validation rules and reject non-conforming reports, which the reporting counterparty must correct and resubmit. #

They can, depending on registration status and the cross-border rules. Non-US firms registered as swap dealers report their swaps under Parts 43 and 45 regardless of where they are based. Unregistered non-US firms are generally only drawn into scope for swaps with US persons — and in most such pairings the US or registered counterparty sits higher in the reporting hierarchy and reports. Substituted compliance determinations can also modify obligations for non-US SDs. #

The Unique Product Identifier (UPI) is a 12-character ISO 4914 code, issued by ANNA-DSB, that identifies an OTC derivative product for regulatory reporting. The CFTC was the first regulator to mandate it: UPIs became required in swap reports from 29 January 2024 for the credit, interest rate, FX and equity asset classes. The EU, UK, Australia and Singapore followed during 2024, making the UPI a global reporting standard. #

Since the Rewrite, a reporting counterparty that discovers an error or omission in its swap data must correct it as soon as technologically practicable, and in any event within seven business days of discovery. If it cannot remediate within that window, it must notify the CFTC with an initial assessment and a remediation plan. This formalised deadline makes systematic exception management and resubmission tracking a practical necessity for CFTC reporting firms. #

The ASIC Rewrite took effect on 21 October 2024, when the ASIC Derivative Transaction Rules (Reporting) 2024 replaced the 2022 rules. The Rewrite aligned Australian OTC derivative reporting with global standards: ISO 20022 XML messaging, the UTI, the UPI and harmonised critical data elements (CDE). Singapore's MAS implemented its equivalent revised reporting requirements on the same date, allowing firms in both jurisdictions to upgrade once. A smaller second tranche of ASIC rule changes follows in October 2025. #

Reporting entities under the ASIC rules include Australian financial services licensees, Australian ADIs (banks), CS facility licensees, and certain foreign entities such as foreign ADIs with an Australian branch. In-scope entities must report their OTC derivative transactions and positions in interest rate, FX, credit, equity and commodity (non-electricity) asset classes. Exchange-traded derivatives on licensed markets are outside the OTC regime. #

OTC derivative transactions must be reported by T+1 — the end of the business day following execution, modification or termination. Lifecycle events and valuation and collateral updates follow the same next-day standard. Reports are submitted to a licensed Australian derivative trade repository in ISO 20022 XML, and rejected submissions must be corrected and resubmitted promptly to keep the entity's reporting complete. #

Yes — a reporting entity may appoint a delegate, such as its counterparty, a broker or a third-party provider, to submit reports on its behalf. The ASIC rules include a safe-harbour provision: the entity is taken to have complied if it has a legally binding delegation agreement and takes reasonable steps, including regular checks, to ensure the delegate is reporting correctly. Responsibility for the obligation itself remains with the reporting entity. #

DTCC Data Repository (Singapore) Pte Ltd (DDRS) is the licensed Australian derivative trade repository used for ASIC OTC derivative reporting. Reporting entities submit their transaction, valuation and collateral reports to DDRS in ISO 20022 XML, and DDRS applies ASIC's validation rules, rejecting non-conforming submissions. Firms should verify current licensing on ASIC's derivative trade repository register. #

Yes — since the Rewrite on 21 October 2024, ASIC reports must carry a Unique Transaction Identifier (UTI), generated and shared according to the international UTI waterfall, and a Unique Product Identifier (UPI) issued by ANNA-DSB for OTC derivative products. These replace the previous mix of trade identifiers and product taxonomies, and align ASIC reports with the CFTC, EU and UK regimes — simplifying multi-jurisdiction reporting for globally active firms. #

Both regimes require T+1 reporting of OTC derivatives with UTI, UPI and ISO 20022 XML, but they differ in structure. ASIC reporting is effectively single-sided in many cases through delegation and its safe harbour, covers OTC derivatives only, and uses one licensed trade repository. EMIR is strictly two-sided with TR reconciliation, covers exchange-traded derivatives as well, and offers a choice of trade repositories. Field sets overlap heavily through CDE but are not identical. #

Alternative reporting — the pre-Rewrite mechanism that let certain foreign entities satisfy ASIC obligations by reporting under an equivalent foreign regime tagged for ASIC — was phased out under the 2024 rules. Foreign reporting entities now generally report under the ASIC rules themselves, directly or through a delegate. Firms that previously relied on alternative reporting should confirm their current obligations against the ASIC Derivative Transaction Rules (Reporting) 2024. #

No. Under EMIR and UK EMIR, delegating submission does not transfer the legal obligation — the delegating counterparty remains responsible for the accuracy and timeliness of its reports and must supervise its delegate. The single exception is the mandatory allocation under EMIR Refit: a financial counterparty facing a small non-financial counterparty (NFC-) is responsible and legally liable for reporting their OTC derivatives on behalf of both parties. #

No. An ARM (Approved Reporting Mechanism) is a regulated conduit that routes MiFIR transaction reports to the regulator. Assisted reporting is a service model: a provider prepares, validates and manages reports across regimes, with submission made under the firm's own TR or ARM arrangements. A firm using assisted reporting for MiFIR will still submit through an ARM — the assisted provider manages the process around it. #

Counterparty delegation is often bundled with execution and can appear free, which makes it attractive at low volumes. At scale, apparent savings erode: fragmented delegation across dealers, supervision effort, and the cost of remediating undetected errors. Assisted reporting carries an explicit service fee plus direct TR/ARM fees, but concentrates all regimes and counterparties into one controlled process. The honest comparison is total cost of compliance, including error remediation and oversight time, not headline fee. #

At minimum: the exact scope of trades and regimes covered, data responsibilities on each side, timeliness commitments against the T+1 deadline, error and rejection handling, the information the delegate will provide to evidence the firm's oversight (submission logs, NACKs, reconciliation results), liability and indemnity terms, and exit provisions including data return. Under the ASIC rules, a legally binding agreement plus regular checking is a condition of the safe harbour. #