538. As indicated in section 5.9 there are two alternative approaches to construct the TSR from the perspective of the field "Event date". Alternative A would entail sequential chronological order derived from the interaction between field "Reporting timestamp" and field"Event date", whereas alternative B would entail chronological order obtained solely from the field "Event date".

539. Alternative A: TRs take into account the events that took place on the same day or the day before for the purpose of constructing the TSR and they update the TSR based on the chronological order of submission from these two days. There is a Need to restamp the latest state. This approach has been implemented under SFTR.

540. The advantages of this approach are:

a. It removes part of the complexity of treatment by the TRs of late reports,

b. It keeps the obligation for correct and timely reporting at the level of the counterparties and the entities responsible for reporting,

c. It is consistent with SFTR logic hence easier to be implemented by TRs and counterparties.

541. The disadvantages of this approach are:

a. it requires counterparties to introduce workarounds to account for specific scenarios, e.g. when counterparties report late and no other event took place in the meantime,