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

INTERVIEW Martin Sadleder- Treamo Business Consulting

Trésorier/Treasurer magazine - N°84 - Jan/Feb/Mar 2014