Investment Managers’ Reporting Obligations Under the E.U. Securities Financing Transactions Regulation

The E.U. Securities Financing Transactions Regulation (SFTR) introduces a reporting obligation for certain counterparties to securities financing transactions. The reporting obligation applies in stages, starting in April 2020 and extending to January 2021. For alternative investment funds (AIFs); undertakings for the collective investment in transferable securities (UCITS) structures; or any trading vehicles owned by an AIF or UCITS structure that fall within the scope of the SFTR reporting requirement, the most relevant phase-in dates will be within the next eight months. In a guest article, Leonard Ng and Chris Poon, partner and senior associate, respectively, at Sidley Austin, discuss the SFTR, including listing the entities that must report, the types of transactions included, the information that must be reported and the reporting start dates. In addition to providing next steps under SFTR, the article also explores the effect of the coronavirus pandemic on that regulation. For more on UCITS structures, see “How Managers Can Launch and Market UCITS Funds in the E.U. and Across the Globe” (Apr. 11, 2019). For additional commentary from Ng and Poon, see “Implications for Investment Managers of the New E.U. Investment Firm Prudential Regime” (Jul. 11, 2019).

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