234. In the Consultation Paper ESMA proposed a new structure for the tables of fields, including i.e. the following changes:

a. additional Table 3 for reporting of margins (in line with SFTR);

b. moving data elements related to valuation from Table 1 (Counterparty data) to Table 2 (Common data);

c. changes in order of assignment of certain data elements to sections of the Table 2, with a view to group similar data elements together and make the table more transparent.

235. Furthermore, ESMA clarified the reasons behind the higher number of data fields and added, for information purposes, an additional column "CDE/UPI" flagging the fields that are either included in the CDE guidance or are expected to be covered by the UPI reference data.

236. Overall, the clarifications and the proposed changes in the structure of the tables were welcomed, in particular including a separate table for margins and moving some of the data elements from Table 1 to Table 2.

237. One respondent stated however that it would be helpful to indicate explicitly in Article 4 of the RTS that Table 3 (Margin data) is to be used for reporting of collateral for both centrally cleared and non-cleared contracts, which is in contrast with SFTR. ESMA clarifies that this remark is indeed correct, and the respective precision has been added to the technical standards.