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Version date: 17 December 2020 - onwards

6.3.2 Summary of feedback on EoD reports (paras. 621-634)

621. One respondent proposed that trade state report should be separated from OTC trades, ETD positions and ETD trades. ESMA confirms that there will be a single trade state report.

622. Another respondent highlighted the divergent technological capacity of NCAs concerning the processing and analysing of TR data and asked to keep a flexible approach. ESMA proposes to retain the optionality for non-XML reports.

623. Following a proposal that TRs could distribute trade state report to reporting participants in the similar way and formats than regulators. ESMA confirms that the trade state report will be the same for counterparties, ERR, RSE and authorities.

624. A respondent recommended the reconciliation status report to be a rolling 30 days report of reconciliation records submitted rather than all outstanding derivatives because (i) outstanding long-lived derivatives are usually not re-reconciled so continuing to include it on the report is not useful; (ii) the file size including the legacy outstanding derivatives would become very large and difficult to differentiate between new issues and legacy issues that have been subsequently resolved; (iii) comparison of a snapshot each month of the submissions for the previous month would allow better monitoring of progress in reconciliation break resolution with counterparties. ESMA disagrees and confirms that outstanding derivatives bear risks and should always be reconciled.

625. Furthermore, the respondent recommended to include more granular error codes in the rejection report. ESMA agrees with this proposal.