389. When reporting IRS, the counterparties should describe the underlying fixed or floating rates in the dedicated rate fields for leg 1 and leg 2 (fields 79-110), rather than e.g. providing the floating rate in the underlying index field.

390. ESMA seeks input on whether the counterparties should be required to agree which leg is reported as leg 1 and which as leg 2 or whether- if both legs are reported consistently -the TRs should be able to reconcile them irrespective of the order. For further details on this aspect please refer to the section 8.2.4.

391. There are three distinct fields to describe a floating rate:

a. Identifier (fields 83 and 99), which should be populated with ISIN,

b. Indicator (fields 84 and 100) which should be populated with a standardised 4- letter code, and

c. Name (fields 85 and 101), which should be populated with the full name of the rate.

392. Counterparties should always report ISIN and 4-letter code, to the extent that they are available for a given rate. The name of the rate should be reported in all cases.

393. Example: A single currency fixed-to-floating 5-year IRS on 3M EURIBOR vs 0.5% (with no additional spread). Counterparties exchange payments each six months and reset frequency is set to annual. The day count convention is Actual/360.