Market participants are required to backload their trades. For the backloading, is it enough to report a contract once or should we do monthly executions on this specific contract for the duration of the contract in the past also?
As an example: we report a bilateral contract, which runs from 01.01.2010 until 31.12.2020. For the Backloading, would it be sufficient to report the contract once with the non standard contract Template and do the monthly execution from April 2016 on? Or should we report the monthly executions with the std contract Template for the time in the past (01.01.2010-01.04.2016), which in this example would mean 75 execution reports.
Please refer to FAQ. 3.6.2:
Any outstanding contract has to be reported as back loaded. Execution under the framework of non-standard contracts concluded before the 7 April 2016 do not fall under the scope of back-loading.
Executions under the framework of non-standard contracts should be reported with Table 1 and linked to non-standard contracts that have already been reported to the Agency with Table 2. See examples in Annex II to the TRUM.
Since there is a three-month period time for the back loading of outstanding non-standard contracts, the reporting of transaction executed under the framework of non-standard contracts are reportable if they take place after the reporting of the back loaded report.