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The key change in the implementation timeline relates to the registration of the first trade repositories (TRs) which was not expected to occur until at least the 24 September. ESMA now expects to make those first registration decisions on 7 November. Consequently, counterparties’ reporting to trade repositories is not expected to start before February 2014.
The change in the timetable is related to a combination of factors including issues faced by the applicants in ensuring the completeness of their applications.