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Version date: 6 January 2020 - onwards

3.2 Reporting of CCP-cleared SFTs

Q12. Having in mind that position reporting of CCP-cleared SFTs is optional only when transaction-level reporting was made in accordance with paragraph 84, do you believe that additional clarifications need to be provided by ESMA? Please detail the reasons for your response.

103. In line with EMIR derivative reporting [The conditions are defined in EMIR Q&As (TR Question 17)], ESMA established in the RTS the optional and complementary position-level reporting for CCP cleared SFTs. Reports at position level can be submitted when the following conditions are met:

a. The legal arrangement is such that the risk is at position level, the trade reports all relate to products that are fungible with each other and the individual trades have been replaced by the position. This is the case when novation takes place after netting of individual trades, the netted position results in a new contract, and a new UTI is generated for it. This could be the case for example, between a clearing member

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