4.4.2.3 Beneficiary and Trading Capacity (paras. 269-300)
296. ESMA proposed in the Consultation Paper the elimination of the fields 'Beneficiary ID' and 'Trading capacity' affirming that the first one in most cases overlap the 'Reporting counterparty' field while the 'Trading capacity' field is always reported as "Principal".
297. With reference to the 'Beneficiary ID' field, overall respondents to the consultation agreed with the ESMA proposal to remove the field since it is not adding any additional information to the reporting.
298. One respondent, notwithstanding the support to the elimination of the field, raised a reporting scenario that may be missed with the removal of the 'Beneficiary ID'. The case concerns ETDs where the clearing member will not enter into a relationship with certain clients of the firm, so the firm itself would step into the contract on their behalf. However, ESMA is of the opinion that the risk lies in the first instance within the firm who will report its contract with the clearing member identifying itself as reporting counterparty and will also report its contract with its client, where the latter will be identified as the other counterparty.