The EU financial markets regulator has withdrawn the registrations of six UK-based credit rating agencies and four trade repositories due to Brexit.
The UK entities of Fitch and Moody’s are among the rating agencies in the action taken by the European Securities and Markets Authority (Esma). However, many of the firms continue to offer services in the EU through European entities.
This includes Fitch and Moody's who, according to an Esma register, have entities registered with the European regulator in Ireland in the case of Fitch, and France and Italy (among others) in the case of Moody's.
In the case of trade repositories the withdrawal of registration means the UK entities can no longer be used for derivatives and securities financing transactions reporting to Esma under the 'Emir' and 'SFTR' regulations, although they can still report UK Emir and UK SFTR to the UK regulator, the Financial Conduct Authority.
DTCC Derivatives Repository Plc still reports to the FCA in the UK, but sister company DTCC Data Repository (Ireland) PLC now does so for Esma. UnaVista Limited, another trade repository, has also registered Unavista TRADEcho BV (Netherlands) for EU purposes.
Val Wotton, a managing director at DTCC, said that so far since January 1, "reporting has run smoothly and clients were well prepared for the new reporting arrangements".
Esma’s action follows the end of the transition period of the UK’s withdrawal from the EU, which occurred on December 31, 2020.
In March 2019, Deutsche Bourse, which owns Luxembourg-based trade repository Clearstream, set up Regis-TR UK, a UK-based trade repository. The company said this had started reporting services for UK clients under Emir this week.
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