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In support of this request, the letter includes concrete examples of the significant challenges that the COVID-19 pandemic and the related measures pose to members’ SFTR implementation projects.
The associations would like to ask ESMA to initiate, as a matter of urgency, the procedure for obtaining a formal delay of the SFTR reporting go-live date to an appropriate date that falls well outside the expected critical phase of the pandemic. They suggest that this could be 11 October 2020, the reporting start date for the third phase of SFTR reporting. In the absence of a formal delay, we would ask ESMA, at a minimum, to consider equivalent measures that would provide forbearance and sufficient reassurance for firms that they are not expected by ESMA and their respective NCA to ensure strict compliance with SFTR reporting obligations for an appropriate period of time following the legal reporting start date. Again, the October start date would seem to be a reasonable reference point.