72. With regard to the provisions under Article 9(2) of the ITS on reporting, ESMA considers that, in order to fulfil the respective requirements, NFC- and FC should agree on the way to exchange information in each of these cases. More particularly, with regard to Article 9(2)(a) of the ITS on reporting, those arrangements should allow the FC to have the information no later than T+1 after the conclusion or modification of a contract so that the FC can proceed to the timely reporting. This can be achieved e.g. by providing a list of predefined standard values to be used as default by the FC, unless specified otherwise by the NFC-. In any case the NFC- remains responsible for providing the FC with correct details and the FC is responsible for using the information provided by the NFC-. As an example of predefined values, consider the case where an NFC- is entering into derivative contracts with a credit institution without the use of a broker, not clearing those contracts and entering into them only to hedge its commercial activity in the sense of EMIR Article 10(3). In this case, the NFC- could agree that the FC reports the below pre-defined values in the fields specified in Article 9(2) of the ITS on reporting, unless the NFC- specifically instructs the FC otherwise:

a. 1.15 'Broker ID': blank.

b. 1.16 'Clearing Member': blank.

c. 1.20 'Directly linked to commercial activity or treasury financing': 'True'.