232. One respondent requested further clarity regarding the intraday reporting of lifecycle events for ETDs, for example in the case of give-ups, position transfers or allocation of trades. In line with the clarification made in the paragraph 201, ESMA clarifies that the intraday reporting of changes in ETD positions is not required. Furthermore, with regard to give-ups ESMA plans to retain the existing guidance provided in the ETD Q&A 3: "Where a give up occurs from the investment firm to the clearing member within the T+1 reporting deadline and there has not been any change of the economic terms of the original trade the trade should be reported in its post give up state". At the same time, it should be reiterated that relevant events impacting derivatives reported at trade level must be reported accordingly (e.g. allocation of trades).

233. Two respondents commented that for ETDs it is the position that is relevant for the assessment of systemic risk, therefore the ETD reporting should be required at least at a position level / only at position level. This suggestion is not in line with EMIR that requires all counterparties to report i.e. conclusion of a derivative.