Q3. Do you agree with the inclusion of the on reconciliation and Rejections data in the waterfall described in Guideline 15? Which other aspects need to be considered? Please elaborate on the reasons for your response.

18. In the CP, ESMA proposed that all data on reconciliation and rejections generated by the old TR related to a derivative subject to transfer should be transferred to the new TR.

19. Six replies were received for this question.

20. All six respondents agreed to the general idea of the proposal. However, some respondents were not supportive of the idea of the transfer of rejection and reconciliation data for various reasons, i.e., efficiency of the data transfer process, financial costs for the new TR, providing data access for authorities, different data formats for reconciliation and rejection data etc..

21. The majority of respondents proposed to only port outstanding derivatives in the case of the voluntary scenario which reflects the current practice for voluntary porting.