Q18. Do you agree with the approach for reporting by NFCs? Is there any additional aspect relating to reporting by NFCs that needs to be clarified? Please detail the reasons for your response.
152. Article 33(2)(a)(iv) SFTR provides that non-financial counterparties must comply with the SFTR reporting obligation 21 months after the regulation enters into force.
153. ESMA proposed in the CP an approach for reporting by NFCs. The approach provides that under Article 33(2)(a)(iv) of SFTR, non-financial counterparties must comply with the SFTR reporting obligation 21 months after the regulation enters into force. Ahead of that date, non-financial counterparties are expected to prepare their systems so that they will be ready to fully comply with the obligation on that date.
154. In particular, ESMA indicated that when the SFT is concluded between two NFCs, both of them need to report it to a TR, though they can make use of the possibility to delegate the reporting under Article 4(2) to one
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