434. Taking into account the CDE guidance, ESMA proposed to remove the 'Up-front payment' field from the RTS on reporting and to include instead the following six fields: 'Other payment type' (report either 1 = upfront payment, 2 = unwind of full termination payment, or 3 = principal exchange i.e. exchange of notional values for cross-currency swaps), 'Other payment amount', 'Other payment currency', 'Other payment date', 'Other payment payer', 'Other payment receiver'. These will ensure that different types of non-regular payment can be reported, up-front or otherwise and that it is clear as to what the other payment relates to, the size of the payment, its currency and the direction in which the payment flows.

435. While half of the respondents agreed with ESMA's proposal, one of them drew attention to the general administrative burden as such a significant increase in data fields poses an equally high risk for different interpretations and for reporting errors. ESMA considered that the new fields as defined under CDE Guidance should be sufficiently clear and that they will provide useful information for the payments that occurred during the life of a derivative transaction but are not the regular periodic payments.