533. Since the start of reporting in 2014, the TRs have been reconciling derivatives data following a process that they developed. This process has evolved over time to (i) address identified deficiencies and (ii) to cater for amendments in the reporting rules. The following proposals build on the already existing structure and enhance it.

534. Under EMIR, there are currently two different stages of the reconciliation process that take place.

535. During the first stage, called Intra-TR reconciliation, the TRs should intend to find the derivative in its own databases, based on the UTI and the LEIs of the counterparties, regardless of whether or not both counterparties to each derivative have reported to the given TR. If so, the TR compares the latest state of the reports and notifies the counterparties about the reconciliation status of the derivative.

536. In order to ensure comparability of data and smooth functioning of the reconciliation process, ESMA proposed and respondents agreed that the TRs reconcile only the latest state of a given derivative at the end of a given day. To ensure comparability, the respondents suggested that TRs should do that by using the event date field to determine the effective date of the latest state of the derivative.

537. Furthermore, ESMA confirms the exclusion of internally paired trades from the inter-TR reconciliation process to avoid overloading the inter-TR reconciliation process. In addition, ESMA clarifies that no parallel process for exchange of internally-paired records will be established.