c) Trades open during the outage and closed during the outage:

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Status: Best Practice Finalised, Last Updated: 15/02/2024

Question:
c) Trades open during the outage and closed during the outage:

1. 1. As best practice, agree the Reporting Date bilaterally with your counterparty (cpty) for T or T+1. Trades not sent at the same time and date will not pair and match, not hit the TSR or be presented for reconciliation.
2. 2. If both cptys on both sides can send/report the NEWT on the same day (T or T+1), it should be acknowledged, paired, matched, and update the current trade state report. This example would be a historic event date with a current reporting date on a NEWT.
3. 3. Replayed lifecycles would have historic ED (Event Dates) with a current RD (Reporting Date) and would hit the TAR (trade activity report) only.

   • Where lifecycle events cannot be replayed, a MODI or CORR with a current ED (Event Date) and a current RD (Reporting Date) is required to update the latest TSR report, trigger the pairing & matching process, and be presented for reconciliation.

4. 4. ETRMS need to be submitted with a historical event date (based on actual term date) to be acknowledged with termination and event date aligned.
5. 5. Note that you are sending an ETRM on an OPEN or Fixed Term trade, not a trade with a populated maturity date you are trying to modify or amend.
6. 6. Overall Notes:

   • The key is reporting the NEWT and ETRM with the historic event date.
   • Firms can also report historic MODIs (prior to ETRM) with a historic event date for accurate back reporting/audit. No events are expected to hit TSR (as position is closed).
   • ETRMS should be reported with the actual term date for accuracy.

7. 7. Refer to comments already made under points a) and b) that are also relevant here.

Best Practice:
(SFTR-830)