3.5 Annex I - Procedure for transfer of data at the request of a TR participant under SFTR
Q54. Do you agree with the procedure described in Annex I? Which other aspects need to be considered? Please elaborate on the reasons for your response.
363. ESMA asked whether the respondents agreed with the procedure described in Annex I and which other aspects needed to be considered.
364. One answer in favour of the proposal was received.
365. The TR remarked that the procedure should only cover the transfer of the latest state of outstanding SFTs. In addition, the respondent asked for providing a clear metric to quantify "the latest state of the outstanding SFTs received", given that there is another metric related to the total number of outstanding SFTs. ESMA clarifies that "the latest state of the outstanding SFTs received" is the most up-to-date expression of each of the reportable details of a SFT, hence it is a qualitative characteristic.
366. The participant also observed that this point is not aligned with Guideline 33, which only considers the quantification (and subsequent confirmation) of the total number of outstanding SFTs.
367. ESMA agrees with the observations and has adapted Annex I accordingly.