Trésorier/Treasurer magazine - N°84 - Jan/Feb/Mar 2014 - (Page 10)
ONLINE
FR/EN
VERSION
''WHEN ON THE EMIR ROAD,
DON'T FORGET TO TAKE YOUR
'ROADBOOK' !''
LE MAGAZINE DU TRESORIER / TREASURER MAGAZINE - N°84 - JAN
/ FEV / MAR 2014
EMIR, our destination ahead!
10
EMIR, a familiar word and target, even
if not very exciting to some and not well
understood by others; a major project
that may have the benefit of providing
opportunities to revisit some of our internal processes. A compliance project with
difficulties that arise from a number of
factors: from the allowed implementation
time being too short, from the uncertainties and the lack of guidance on
certain aspects of the regulation
and finally from the lack, on
the face of it, of value added for
treasurers.
As a British soldier would say,
we must not forget the principle
of the five «Ps» (Proper Preparation Prevents Poor Performance). It would seem that we
need to put together a reliable
roadbook before setting out on
the road to complying with the
new EMIR regulation. In this
roadbook, the important thing
would seem to be to decide on
what action we need to take by
category, what stakeholders we
should bring on board, what
technical resources we need to
enhance, subcontractor or put in
place, and the timescale we should allow
for each step of this short but tortuous
and difficult journey.
One major difficulty arises from the fact
that, however good our roadbook may be,
like a rally driver we have to adapt it and
sometimes improvise en route as some of
the stages still look rather unclear. But we
have to make a start and embark on our
project, even if there are still a number of unknowns. We think that things
will become clearer as we move further
down the road. Although it is not the
most usual or the most efficient way of
behaving before setting out on a project,
it is the most realistic if you plan to arrive
at your destination in time. Since no GPS
exists, unfortunately, you have to plan
your own itinerary and adapt it for your
own needs and specific requirements.
EMIR, a group-wide project headed
up by corporate treasury
department
To set up the EMIR reporting system,
or for the less fortunate, to set up the
collateral management system, you
or some of the reporting operations and
finally the Trade Repository (TR) which
will be responsible for reporting to ESMA.
It is important to win the support and
commitment of all stakeholders before
the start of the project.
Stakeholders:
INTERNAL STAKEHOLDERS:
1. CFO
2. Legal department
3. Financial IT department
4. CRO
5. CCO
6. Subsidiaries' CFOs
EXTERNAL STAKEHOLDERS:
have to coordinate different skills and
different expertise, in-house and/or
externally. First you have to obtain the
Chief Financial Officer's (CFO) «signin» to the project and sell it to him, even
though the apparent added value may
be nil. You also have to involve other
departments such as legal department,
financial IT department, Enterprise Risk
Management department (CRO), possibly
the tax department and finally the Chief
Compliance Officer (CCO). Furthermore,
you need to involve other external stakeholders such as the statutory auditors,
internal audit, the main shareholder or
shareholders, external legal advisers, IT
or TMS solutions sellers to outsource all
1. IT vendors (TMS) or
solution
providers
2. Legal advisers/consultants
(if necessary)
3. External auditors
4. Banks
5. Trade repositories
Taking the twists and turns in the
right order
As in a rally, compliance with SEPA is a
«special stage» (as professional drivers
would say): short and intense. You have
to handle several things at the same time
to attain the set target. You have to work
on the various aspects concerned, which
are: the matter of «selling the project
in-house» which is crucial and absolutely essential; the legal aspect, which is
fundamentally important; the financial
information aspect, which is unavoidable; the risk management and compliance aspect; possibly the tax aspect;
the internal and external communication
Table des matières de la publication Trésorier/Treasurer magazine - N°84 - Jan/Feb/Mar 2014
Couverture
SOMMAIRE
EDITORIAL
FINANCIAL HIGHLIGHTS Luxembourg Tax News
INTERVIEW Martin Sadleder- Treamo Business Consulting
FOCUS
FORUM
CORPORATE FINANCE
15 MINUTES WITH CRX Markets
NEWS
THE FINANCIAL RISK OBSERVATORY
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