Small NFC Delegated Reporting

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Status: Best Practice Finalised, Last Updated: 26/04/2021

Question:
If borrowing from a Small NFC through an Agent Lender, will the Agent Lender report on behalf of the Small NFC?

Best Practice:
The regulation passes the reporting obligation on to the borrower, rather than the agent lender, if they are an eligible, EU-domiciled, FC participant. Otherwise, the Small NFC has to perform this or allocate the task to a voluntary delegate.

See ISLA Best Practice SFTR-164 for further detail and references to ESMA Final Report and Guidelines. (SFTR-248)