569. One of the main issues linked to the reconciliation of derivatives relates to the possibility for counterparties to report with a different time schedule the lifecycle events relating to the derivative. This is the case for all derivatives, but the impact is exacerbated in the case of position-level ones. For position level reporting, please refer to section 5.7.

570. For derivatives reported at trade level, TRs should use the latest values for each field subject to reconciliation as determined in accordance with section 8.1.

571. For derivatives reported at position level, TRs should strive to reconcile the derivatives for the latest event date applicable to both counterparties. TRs should avoid including the latest trade state, unless they have a reasonable degree of certainty that both side of the derivative are reported in a consistent way and in accordance with the same timeline by both counterparties, or by the entities reporting on their behalf.

572. TRs therefore should reconcile the positions' latest state as determined by the latest applicable event date, which should be the latest working day which is two working days before the date on which the reconciliation takes place. For instance, in case the reconcilaition takes place on Wednesday, the TRs should include the derivatives reported at position level whose Event date is Monday or earlier. In case the reconcilaition takes place on Monday, the TRs should include the derivatives reported at position level whose Event date is Thursday or earlier. This clarification is not relevant for derivatives that are not outstanding.