9. The existing data TRs make available includes inconsistent calculations of positions across TRs, thus making the aggregation of multiple positions not possible. This prevents authorities from being able to swiftly assess systemic risks to financial stability and quickly react in a crisis event.
10. The possibility for reporting counterparties to report their trades to different TRs poses a particular challenge for the establishment of a set of entity-level positions that is consistent, complete and coherent across entities and derivatives.
11. Specifically, each individual TR may only hold partial information on an entity’s exposure with respect to any product and each of its counterparties. Hence, in some cases TRs can only calculate a partial TR-level position for any entity.
12. Therefore, the determination of an overall entity-level position requires an aggregation of the TR-level positions across several TRs. Overall entity-level positions should be determined by authorities
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