Q38. Do you agree with the approach for back-loading? What other aspects have to be considered to make the reporting of backloaded SFTs more efficient for counterparties and TRs, i.e. the costs of this approach are minimised and also the usefulness of the reports submitted going forward is maximised? Please detail the reasons for your response.
300. SFTR provides that the reporting obligation applies to SFTs concluded before the relevant RSD (which is determined by the type of reporting counterparty) which remain outstanding on that date if their remaining maturity exceeded 180 days, or the SFT had an open maturity and remained outstanding 180 days after the date of application, i.e. Reporting Start Date (RSD) +180. SFTR thus requires that these SFTs are backloaded by reporting counterparties within 190 days of the relevant RSD.
301. ESMA recognises the need to ensure that the reporting of SFTs is done in an efficient manner which (i) enables authorities to receive all the necessary in
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