The same applies where an investment firm operates under a discretionary mandate for a collective investment undertaking and concludes a pension contract on a government bond. In the event that the fund has reporting obligations in accordance with the SFTR and the investment firm is not, in that case, the investment firm under the MiFIR is not required to report transactions, as the transaction was reported after the ASR. On 25 July 2012, ESMA published guidelines on ETFs and other UCITS issues, which contained a consultation document in Annex IV on the possibility of recalling pensions and reverse retirement transactions. The consultation process culminated in the publication on 4 December 2012 of ESMA`s Guidelines for Pension Operations and Reverse Retirement Operations (the «Guidelines»). UCITS in general and MMFs in particular make extensive use of reverse-pension arrangements (i.e.: Funds lend cash and receive securities guarantees), with some lending all of their cash on the terms of these agreements. Repurchase agreements (i.e. funds borrow cash and deposit securities guarantees) are expected to be of great interest to funds that will have to deposit cash guarantees with clearing houses when mandatory clearing of OTC derivatives applies from next year. On 4 December 2012, the European Securities and Markets Authority (ESMA) published definitive guidelines on repo and reverse retirement transactions for UCITS funds. This is a consequence of ESMA`s publication in July 2012 of the Guidelines on ETFs and UCITS (see DechertOnPoint) (ESMA Guidelines), which included a consultation on the guidelines that has just been published. For the purpose of reporting on repo transactions, ESMA proposes, as regards the role of counterparties, to use the terms `guarantors` and `collateral takers`. This is because the repo rate is the collateral taker`s return on lending money to the collateral provider. There are different types of rest, depending on the contractual agreements and the parties involved, and the process may involve a broker helping counterparties start trading.

By definition, a reverse repo is the opposite of a repo, that is, first buying assets and then reselling them later. On 4 December 2012, the European Securities and Markets Authority (ESMA) published its final guidelines 2012/722 on UCITS pensions and reverse retirement operations. These guidelines follow the consultation published in ESMA`s report and Consultation Document 2012/474 on the `revocability` of reverse and reverse representative agreements, published on 25 July last and containing guidelines on ETFs and other UCITS matters. . . .