ESMA struggles to hit the spot in terms of tackling the most pressing issues with its latest Q&As but there is some benefit for reporting firms from Q&A 14, published alongside Q&A 13 on 19 July 2022.
Q&A 14 clarifies the requirements around reporting collateral and validation updates on the last day of an SFT (including overnight and intraday transactions). The answer is that firms should not send either collateral or valuation updates for the last day of an SFT. In the case of intraday transactions, the day of conclusion (execution date) is the last day of the SFT. For overnight transactions, counterparties should report valuation and collateral updates for trade date (T).
The second Q&A 13 applies to trade repositories, reiterating that they need to include SFTs in the trade state report up until their maturity date / end date unless they have been errored or early terminated.
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