SWISS FMIA (FinfraG) Reporting Regulation

The Swiss Financial Market Infrastructure Act (FMIA), or ‘FinfraG’, requires firms with their registered office in Switzerland to report their derivatives trades to regulators. The most comparable EU regulatory requirement is EMIR reporting. Regulatory Reporting partnered with the industry and SIX, the Swiss stock exchange, to use its EMIR expertise to construct the field requirements for Swiss reporting. 

However, there are a number of differences between the two that mean it can be difficult for firms to easily meet both sets of requirements using in-house software. LSEG Post Trade's G20 Regulatory Reporting product can assist firms to easily and efficiently satisfy these and other reporting obligations using the same input files.

Only counterparties with a registered office in Switzerland are required to report (as will their foreign branches), regardless of the instrument traded.

The reporting obligation is single-sided, and the reporting counterparty is chosen as follows:

• If the trade is cleared, the central counterparty must report, unless this central counterparty is ineligible for reporting (Highest priority for reporting)
• If the trade is un-cleared and between a financial counterparty and a non-financial counterparty, the financial counterparty reports
• If the trade is un-cleared and between two financial counterparties:
• The financial counterparty that isn’t small* reports (assuming 1 is not small)
• The seller reports, if the transaction is between two small or two non-small financial counterparties
• The counterparty which has its registered office in Switzerland (if one counterparty does)
• If the trade is un-cleared and between two non-financial counterparties, the same three criteria apply as for un-cleared trades between two financial counterparties. The only exception to this is that un-cleared trades between two small non-financial counterparties don’t need to be reported

Both OTC and exchange-traded derivatives from the following asset classes need to be reported:

• Credit
• Commodities (excluding electricity and gas derivatives trading on-exchange with only physical delivery as a settlement option, and also excluding freight, inflation, and climate derivatives)
• Equities
• FX
• Rates

FinfraG also makes an exemption for “other official economic statistics that are settled in cash only in the event of a default or other termination event”.

T+1, the day after the trade is executed, or the day after the trade is modified or terminated for lifecycle events. Valuations must be reported daily for outstanding trades and positions (apart from those conducted with small counterparties).