Q78. Do you agree with the approach to reporting margin data? Please detail the reasons for your response and include a reference to the specific table.
506. ESMA asked for feedback on the approach to reporting margin data. Margin information is applicable only to CCP-cleared SFTs. In the case shown in Table 102 of the CP, the entity uses the same portfolio for collateralisation as under EMIR. The reporting counterparty, Counterparty J, which is also a clearing member uses delegated reporting services provided by Counterparty D. It reports initial margin and variation margin posted to CCP O. The counterparty also reports excess collateral.
507. Three out of thirteen respondents fully supported the proposal. Many respondents pointed out a mistake in the table where the two counterparties were switched around. There were several requests for clarifications predominantly from CCPs. It was pointed out that some CCPs do not have the concept of variation margin. It was asked if the variation
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