Q45. Do you agree with the approach to reporting action types? Please detail the reasons for your response and include a reference to the specific table.
357. Many respondents asked for clarification about certain aspects related to position level reporting: i) if position reporting is optional, since in the examples it seems that all cleared trades are reported like this, ii) if counterparties will need to agree on which trades would be reported as a position level iii) if according to the tables described in the CP, reporting "Position Component" as an action type at transaction level is the previous step of reporting "New" as an action type and at position level, and iv) a CCP stated that position level reporting applies only if the CCP´s model supports it.
358. ESMA would like to emphasise that the counterparties are allowed to report optionally a single position-level STF when certain conditions, as described in the Section on "Reporting of CCP-cleared SFTs" of the CP, are met. D
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