Q17. Is the proposed guidance for reporting of intragroup SFTs clear and comprehensive? Which areas require further clarification? Please detail the reasons for your response.
147. An intragroup transaction is a transaction between two undertakings which are included in the same consolidation on a full basis and are subject to appropriate centralised risk evaluation, measurement and control procedures. There are no exemptions in relation to reporting of intragroup SFTs by counterparties subject to the reporting obligation under
148. Article 4 SFTR. Therefore, when an intragroup SFT is concluded, the counterparties should report it in accordance with Article 4 SFTR.
149. ESMA proposed in the CP guidance for reporting of intragroup SFTs. Respondents did not provide specific comments in relation to this item.
150. Against this backdrop, the Guidelines include the elements provided in the CP.
151. Finally, due to lacking legal basis, ESMA is not taking into account the general suggestion m
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