3.3 EMIR Tables of fields (paras. 393-425)
3.3.1 Table 1 Counterparty data
Q78: Do you agree with the population of the counterparty data fields? Please detail the reasons for your response and indicate the table to which your comments refer.
Q79: Is there any other use case related to the population of counterparty data which requires clarifications or examples? Please detail which one and indicate which aspect requires clarification.
393. In relation to section related to counterparty data reporting, overall the respondents welcomed and supported the examples provided and requested some minor clarifications.
394. In particular, one respondent requested to clarify whether the daily reports to be reported to TR should be referred to: a) 2 reports per counterparty data and 1 report per trade data + collateral or b) 2 reports per counterparty data and 2 reports per trade data + collateral, as provided for SFTR reporting. On this ESMA clarifies that, as per Article 1(4) of the RTS on reporting, where one report is made on behalf of both counterparties, it shall contain the details set out in Tables 1, 2 and 3 of the Annex in relation to each of the counterparties. Therefore, just the solution under letter b) of this paragraph is acceptable.