Q42. Do you agree with this approach? What other aspects need to be considered? Please elaborate on the reasons for your response.
337. Article 33(2)(a) SFTR sets out a staggered approach to the reporting start date. This is expected to facilitate the implementation of the reporting by entities that are not as frequent users of SFTs, such as the NFCs.
338. Therefore, in this interim period, the SFTs that are concluded between two counterparties, one for which the reporting obligation has kicked in and another one for which it has not, cannot be reconciled, as they are reported only by one of the counterparties.
339. ESMA stated that the counterparties for which the reporting obligation has not yet started should provide the counterparty for which the reporting obligation has commenced with all the relevant information in accordance with the TS on reporting
340. Secondly, should the counterparties who are not required to begin reporting in the initial phase (from April 2020) find it eas
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