4.3.1.2 Sequences of action types (paras. 210-217)
210. Respondents generally welcomed the chart showing the allowable sequences of action types and their impact on the status of the derivative (see Figure 1 in the Consultation Paper). Some respondents suggested providing more specific examples to show expected sequences for reports in different business scenarios. ESMA expects to provide more detailed examples in the future guidelines on reporting.
211. A few respondents asked about reporting of lifecycle events for ETDs, given that after the report with action type 'Position component' the trade would no longer be outstanding. ESMA reiterates that where a trade is included in the position, any subsequent lifecycle events must be reported at position level.
212. Two respondents asked whether the trades that are non-outstanding should be subject to reconciliation or not and whether the log of reconciliation failures would apply to these trades. ESMA clarifies that only trades that are outstanding or were outstanding up to 30 calendar days before are subject to reconciliation. As for the log of reconciliation failures, pursuant to the feedback received from the industry, ESMA decided not to include the requirement to maintain such log. For further details please refer to the sections 5.3.1 and 4.1.4 respectively.