Q51. 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.

339. 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.

340. All four respondents agreed with the proposed Guideline.

341. One TR proposed that details on scenarios should be defined by products.

342. Another respondent requested further clarifications on the relationship between Guideline 33 and Guideline 8.

343. Two TRs remarked that the unique identification of reports should be done differently.

344. One TR stated that the timeline would need to be reconsidered and that this would be difficult for participants.

345. One TR mentioned that the differences in record keeping requirements for TR participants (5 years) and TRs (10 years) may result to the incapacity for TR Participants to confirm the aggregate information in many circumstances.