October 2017

Please find enclosed our firm's latest Newsflash on the new trade reporting regime for derivatives and structured products, which will become effective on October 1, 2018 (with a backloading obligation for trades executed between January 1 and September 30, 2018).

Under FINMA's new regulations, certain forms of derivatives and structured products must be "looked through" for trade reporting purposes. Thus, if the weighting of an underlying is significant (>25%) and the underlying is traded on a Swiss trading venue, the trades in the relevant financial instrument will have to be reported, even if the financial instrument itself is not admitted to trading on a Swiss trading venue.

The attached document discusses some of the ramifications of this new regime.