367. In order to ensure comparability of data and smooth functioning of the reconciliation process, ESMA proposes that the TRs reconcile only the latest state of a given derivative at the end of a given day. This includes the relevant data elements of the counterparty data set and the common data set.

368. Since the start of reporting in 2014, the TRs have been reconciling derivatives data. This has been done following a process that was developed by the TRs, and that has evolved over time to (i) address identified deficiencies and (ii) to cater for amendments in the reporting rules.

369. Currently, there are two different stages of the reconciliation process that take place under EMIR. The proposals in this respect build on the already existing structure and enhance it.

370. During the first stage, called Intra-TR reconciliation, the TRs should intend to find the derivative in its own databases, based on the UTI and the LEIs of the counterparties, regardless of whether or not both counterparties to each derivative have reported to the given TR. If so, the TR compares the latest state of the reports and notifies the counterparties about the reconciliation status of the derivative.

371. Only after the completion of the intra-TR reconciliation process, those trades for which no other side has been found are included in the second stage called inter-TR reconciliation.

Q107. Are there any aspects related to the intra-TR reconciliation that need to be clarified? Please detail the reasons for your response.