Q11. Do you agree with confirmation of the aggregate information by the TR participants or the entities reporting on their behalf prior and after the data transfer? Which other aspects need to be considered? Please elaborate on the reasons for your response.

106. ESMA proposed that the counterparties or the entities reporting on their behalf perform a verification and confirmation of the correctness of the aggregate information prior and after the transfer of data.

107. Seven responses were received.

108. Six respondents generally supported the proposal, one respondent rejected the proposal.

109. One participant could not see any benefit in this validation process by the TR participant and asked ESMA to explain the benefits.

110. Several TRs remarked that data under (ii) to (iv) should only be ported in the case of withdrawal of registration.

111. Some TRs expressed their concern that a TR participant only has one day to verify the data, which may prove difficult, e.g. for NFC-entities with limited resources dedicated to reporting. The TR asked for clarification whether it should proceed with the porting processes in case it does not receive a confirmation by the TR participant or not.