3.2.3.1 Scope of the data to be transferred in the case of withdrawal

Q36. Do you agree that in the case of withdrawal of registration of a TR, the transfer of data should comprise all the details of SFTs reported to the TR, including the rejected ones, together with the relevant reporting log, and all data on rejections at file level and all data on reconciliation status for the purposes of the inter-TR reconciliation process at transaction level? Which other aspects need to be considered? Please elaborate on the reasons for your response.

251. For the case of withdrawal of registration, ESMA proposed that the data transfer comprise all the details of SFTs reported to the TR, including the rejected ones, together with the relevant reporting log, and all data on rejections and on reconciliation generated by the old TR.

252. Three responses were received.

253. All respondents disagreed with the proposal as regards the inclusion of rejected SFTs and/or reconciliation data.

254. One TR argued that the storage and reporting based on the LEI of a rejected SFT would be sufficient for the inter-TR reconciliation process.

255. Another TR stated that the effort of storing rejected SFTs reconciliation data outweighed the benefits.