3.4.1 Trade State Report

3.4.1.1 Introduction

426. Following to the feedback received, this section of the Guidelines was updated with a clarification concerning the provision of TSR to counterparties and authorities in cases where e.g. valuation data is submitted by a different report submitting entity.

3.4.1.2 Treatment of event date

Q83. Which of the two approaches provides greater benefits for data reporting and data record-keeping? Please elaborate on the reasons for your response.

Q84. In case Approach B is followed, should the TRs update the TSR when counterparties have reported lately the details of derivatives? If so, do you agree with the time limit ten years for such an update? Please elaborate on the reasons for your response

427. ESMA proposed two alternative approaches to construct the TSR from the perspective of the field 'Event date'. Alternative A would entail sequential chronological order derived from the interaction between field 'Reporting timestamp' and field 'Event date', whereas alternative B would entail chronological order obtained solely from the field 'Event date'.