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Commission Implementing Regulation (EU) 2019/363Show full title

Commission Implementing Regulation (EU) 2019/363 of 13 December 2018 laying down implementing technical standards with regard to the format and frequency of reports on the details of securities financing transactions (SFTs) to trade repositories in accordance with Regulation (EU) 2015/2365 of the European Parliament and of the Council and amending Commission Implementing Regulation (EU) No 1247/2012 with regard to the use of reporting codes in the reporting of derivative contracts (Text with EEA relevance)

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Commission Implementing Regulation (EU) 2019/363, ANNEX II is up to date with all changes known to be in force on or before 08 August 2024. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations. Help about Changes to Legislation

EUR 2019 No. 363 may be subject to amendment by EU Exit Instruments made by both the Financial Conduct Authority and the Bank of England under powers set out in The Financial Regulators’ Powers (Technical Standards etc.) (Amendment etc.) (EU Exit) Regulations 2018 (S.I. 2018/1115), regs. 2, 3, Sch. Pt. 5. These amendments are not currently available on legislation.gov.uk. Details of relevant amending instruments can be found on their website/s.

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Changes and effects yet to be applied to Annex II:

ANNEX IIU.K.

The Annex to Implementing Regulation (EU) No 1247/2012 is replaced by the text below.

ANNEX

Table 1

Counterparty Data

a

Directive 2009/138/EC of the European Parliament and of the Council of 25 November 2009 on the taking-up and pursuit of the business of Insurance and Reinsurance (Solvency II) (OJ L 335, 17.12.2009, p. 1).

b

Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms, amending Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC (OJ L 176, 27.6.2013, p. 338).

c

Directive 2004/39/EC of the European Parliament and of the Council of 21 April 2004 on markets in financial instruments amending Council Directives 85/611/EEC and 93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 93/22/EEC (OJ L 145, 30.4.2004, p. 1).

d

Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010 (OJ L 174, 1.7.2011, p. 1).

e

Directive 2003/41/EC of the European Parliament and of the Council of 3 June 2003 on the activities and supervision of institutions for occupational retirement provision (OJ L 235, 23.9.2003, p. 10).

f

Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS) (OJ L 302, 17.11.2009, p. 32).

g

Regulation (EC) No 1893/2006 of the European Parliament and of the Council of 20 December 2006 establishing the statistical classification of economic activities NACE Revision 2 and amending Council Regulation (EEC) No 3037/90 as well as certain EC Regulations on specific statistical domains (OJ L 393, 30.12.2006, p. 1).

FieldFormat
Parties to the contract
1Reporting timestampISO 8601 date in the format and Coordinated Universal Time (UTC) time format YYYY-MM-DDThh:mm:ssZ
2Reporting Counterparty IDISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code.
3Type of ID of the other Counterparty

‘LEI’ for ISO 17442 Legal Entity Identifier (LEI)

‘CLC’ for Client code

4ID of the other Counterparty

ISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code.

Client code (up to 50 alphanumerical digits).

5Country of the other CounterpartyISO 3166 – 2 character country code
6Corporate sector of the reporting counterparty

Taxonomy for Financial Counterparties:

A = Assurance undertaking authorised in accordance with Directive 2009/138/EC of the European Parliament and of the Councila

C = Credit institution authorised in accordance with Directive 2013/36/EU of the European Parliament and of the Councilb

F = Investment firm authorised in accordance with Directive 2004/39/EC of the European Parliament and of the Councilc

I = Insurance undertaking authorised in accordance with Directive 2009/138/EC

L = Alternative investment fund managed by Alternative Investment Fund Managers (AIFMs) authorised or registered in accordance with Directive 2011/61/EU of the European Parliament and of the Councild

O = Institution for occupational retirement provision within the meaning of Article 6(a) of Directive 2003/41/EC of the European Parliament and of the Councile

R = Reinsurance undertaking authorised in accordance with Directive 2009/138/EC

U = Undertakings for the Collective Investment in Transferable Securities (UCITS)and its management company, authorised in accordance with Directive 2009/65/EC of the European Parliament and of the Councilf

Taxonomy for Non-Financial Counterparties. The following categories correspond to the main sections of Statistical classification of economic activities in the European Community (NACE) as defined in Regulation (EC) No 1893/2006 of the European Parliament and of the Councilg

1 = Agriculture, forestry and fishing

2 = Mining and quarrying

3 = Manufacturing

4 = Electricity, gas, steam and air conditioning supply

5 = Water supply, sewerage, waste management and remediation activities

6 = Construction

7 = Wholesale and retail trade, repair of motor vehicles and motorcycles

8 = Transportation and storage

9 = Accommodation and food service activities

10 = Information and communication

11 = Financial and insurance activities

12 = Real estate activities

13 = Professional, scientific and technical activities

14 = Administrative and support service activities

15 = Public administration and defence; compulsory social security

16 = Education

17 = Human health and social work activities

18 = Arts, entertainment and recreation

19 = Other service activities

20 = Activities of households as employers; undifferentiated goods – and services –producing activities of households for own use

21 = Activities of extraterritorial organisations and bodies

Where more than one activity is reported, list the codes in order of the relative importance of the corresponding activities, separating them with a ‘-’.

Leave blank in the case of CCPs and other type of counterparties in accordance with Article 1(5) of Regulation (EU) No 648/2012.

7Nature of the reporting counterparty

F = Financial Counterparty

N = Non-Financial Counterparty

C = Central Counterparty

O = Other

8Broker IDISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code.
9Report submitting entity IDISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code)
10Clearing member IDISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code
11Type of ID of the Beneficiary

‘LEI’ for ISO 17442 Legal Entity Identifier (LEI)

‘CLC’ for Client code

12Beneficiary IDISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code or up to 50 alphanumerical character client code in the case where the client is not eligible for a Legal Entity Identifier
13Trading capacity

P = Principal

A = Agent

14Counterparty side

B = Buyer

S = Seller

Populated in accordance with Article 3a

15Directly linked to commercial activity or treasury financing

Y = Yes

N = No

16Clearing threshold

Y = Above the threshold

N = Below the threshold

17Value of contract

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

18Currency of the valueISO 4217 Currency Code, 3 alphabetical characters
19Valuation timestampISO 8601 date in the UTC time format YYYY-MM-DDThh:mm:ssZ
20Valuation type

M = Mark-to-market

O = Mark-to-model

C = CCP's valuation.

21Collateralisation

U = uncollateralised

PC = partially collateralised

OC = one way collateralised

FC = fully collateralised

Populated in accordance with Article 3b

22Collateral portfolio

Y = Yes

N = No

23Collateral portfolio code

Up to 52 alphanumerical characters including four special characters: ‘. - _.’

Special characters are not allowed at the beginning and at the end of the code. No space allowed.

24Initial margin posted

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

25Currency of the initial margin postedISO 4217 Currency Code, 3 alphabetical characters
26Variation margin posted

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

27Currency of the variation margins postedISO 4217 Currency Code, 3 alphabetical characters
28Initial margin received

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

29Currency of the initial margin receivedISO 4217 Currency Code, 3 alphabetical characters
30Variation margin received

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

31Currency of the variation margins receivedISO 4217 Currency Code, 3 alphabetical characters
32Excess collateral posted

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

33Currency of the excess collateral postedISO 4217 Currency Code, 3 alphabetical characters
34Excess collateral received

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

35Currency of the excess collateral receivedISO 4217 Currency Code, 3 alphabetical characters

Table 2

Common Data

FieldFormatApplicable types of derivative contracts
Section 2a – Contract typeAll contracts
1Contract type

CD = Financial contracts for difference

FR = Forward rate agreements

FU = Futures

FW = Forwards

OP = Option

SB = Spreadbet

SW = Swap

ST = Swaption

OT = Other

2Asset class

CO = Commodity and emission allowances

CR = Credit

CU = Currency

EQ = Equity

IR = Interest Rate

Section 2b – Contract informationAll contracts
3Product classification typeC = CFI
4Product classificationISO 10692 CFI, 6 characters alphabetical code
5Product identification type

Specify the applicable identification:

I = ISIN

A = AII

6Product identification

For product identifier type I: ISO 6166 ISIN 12 character alphanumerical code

For product identifier type A: Complete AII code

7Underlying identification type

I = ISIN

A = AII

B = Basket

X = Index

8Underlying identification

For underlying identification type I: ISO 6166 ISIN 12 character alphanumerical code

For underlying identification type A: complete AII code

For underlying identification type B: all individual components identification through ISO 6166 ISIN or complete AII code. Identifiers of individual components shall be separated with a dash ‘-’.

For underlying identification type X: ISO 6166 ISIN if available, otherwise full name of the index as assigned by the index provider

9Notional currency 1ISO 4217 Currency Code, 3 alphabetical characters
10Notional currency 2ISO 4217 Currency Code, 3 alphabetical characters
11Deliverable currencyISO 4217 Currency Code, 3 alphabetical characters
Section 2c – Details on the transactionAll contracts
12Trade ID

Up to 52 alphanumerical character code including four special characters:‘. - _.’

Special characters are not allowed at the beginning and at the end of the code. No space allowed.

13Report tracking numberAn alphanumeric field up to 52 characters
14Complex trade component IDAn alphanumeric field up to 35 characters
15Venue of executionISO 10383 Market Identifier Code (MIC), 4 alphanumerical characters, in accordance with Article 4(b).
16Compression

Y = contract results from compression

N = contract does not result from compression

17Price/rate

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

In case the price is reported in percent values, it should be expressed as percentage where 100 % is represented as ‘100’

18Price notation

U = Units

P = Percentage

Y = Yield

19Currency of priceISO 4217 Currency Code, 3 alphabetic characters
20Notional

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

21Price multiplier

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

22Quantity

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

23Up-front payment

Up to 20 numerical characters including decimals.

The negative symbol to be used to indicate that the payment was made, not received.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

24Delivery type

C = Cash

P = Physical

O = Optional for counterparty or when determined by a third party

25Execution timestampISO 8601 date in the UTC time format YYYY-MM-DDThh:mm:ssZ
26Effective dateISO 8601 date in the format YYYY-MM-DD
27Maturity dateISO 8601 date in the format YYYY-MM-DD
28Termination dateISO 8601 date in the format YYYY-MM-DD
29Settlement dateISO 8601 date in the format YYYY-MM-DD
30Master Agreement typeFree Text, field of up to 50 characters, identifying the name of the Master Agreement used, if any
31Master Agreement versionISO 8601 date in the format YYYY
Section 2d – Risk mitigation/ReportingAll contracts
32Confirmation timestampISO 8601 date in the UTC time format YYYY-MM-DDThh:mm:ssZ
33Confirmation means

Y = Non-electronically confirmed

N = Non-confirmed

E = Electronically confirmed

Section 2e – ClearingAll contracts
34Clearing obligation

Y = Yes

N = No

35Cleared

Y = Yes

N = No

36Clearing timestampISO 8601 date in the UTC time format YYYY-MM-DDThh:mm:ssZ
37CCP

ISO 17442 Legal Entity Identifier (LEI)

20 alphanumerical character code

38Intragroup

Y = Yes

N = No

Section 2f – Interest RatesInterest rate derivatives
39Fixed rate of leg 1

Up to 10 numerical characters including decimals expressed as percentage where 100 % is represented as ‘100’.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

40Fixed rate of leg 2

Up to 10 numerical characters including decimals expressed as percentage where 100 % is represented as ‘100’.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

41Fixed rate day count leg 1Numerator/Denominator where both Numerator and Denominator are numerical characters or alphabetic expression ‘Actual’, e.g. 30/360 or Actual/365
42Fixed rate day count leg 2Numerator/Denominator where both Numerator and Denominator are numerical characters or alphabetic expression ‘Actual’, e.g. 30/360 or Actual/365
43Fixed rate payment frequency leg 1 –time period

Time period describing how often the counterparties exchange payments, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

44Fixed rate payment frequency leg 1 – multiplier

Integer multiplier of the time period describing how often the counterparties exchange payments.

Up to 3 numerical characters.

45Fixed rate payment frequency leg 2 – time period

Time period describing how often the counterparties exchange payments, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

46Fixed rate payment frequency leg 2 – multiplier

Integer multiplier of the time period describing how often the counterparties exchange payments.

Up to 3 numerical characters.

47Floating rate payment frequency leg 1 – time period

Time period describing how often the counterparties exchange payments, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

48Floating rate payment frequency leg 1 – multiplier

Integer multiplier of the time period describing how often the counterparties exchange payments.

Up to 3 numerical characters.

49Floating rate payment frequency leg 2 – time period

Time period describing how often the counterparties exchange payments, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

50Floating rate payment frequency leg 2 – multiplier

Integer multiplier of the time period describing how often the counterparties exchange payments.

Up to 3 numerical characters.

51Floating rate reset frequency leg 1 – time period

Time period describing how often the counterparties reset the floating rate, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

52Floating rate reset frequency leg 1 – multiplier

Integer multiplier of the time period describing how often the counterparties reset the floating rate.

Up to 3 numerical characters.

53Floating rate reset frequency leg 2 – time period

Time period describing how often the counterparties reset the floating rate, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

54Floating rate reset frequency leg 2 – multiplier

Integer multiplier of the time period describing how often the counterparties reset the floating rate.

Up to 3 numerical characters.

55Floating rate of leg 1

The name of the floating rate index

‘EONA’ – EONIA

‘EONS’ – EONIA SWAP

‘EURI’ – EURIBOR

‘EUUS’ – EURODOLLAR

‘EUCH’ – EuroSwiss

‘GCFR’ – GCF REPO

‘ISDA’ – ISDAFIX

‘LIBI’ – LIBID

‘LIBO’ – LIBOR

‘MAAA’ – Muni AAA

‘PFAN’ – Pfandbriefe

‘TIBO’ – TIBOR

‘STBO’ – STIBOR

‘BBSW’ – BBSW

‘JIBA’ – JIBAR

‘BUBO’ – BUBOR

‘CDOR’ – CDOR

‘CIBO’ – CIBOR

‘MOSP’ – MOSPRIM

‘NIBO’ – NIBOR

‘PRBO’ – PRIBOR

‘TLBO’ – TELBOR

‘WIBO’ – WIBOR

‘TREA’ – Treasury

‘SWAP’ – SWAP

‘FUSW’ – Future SWAP

Or up to 25 alphanumerical characters if the reference rate is not included in the above list

56Floating rate reference period leg 1 – time period

Time period describing reference period, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

57Floating rate reference period leg 1 – multiplier

Integer multiplier of the time period describing the reference period.

Up to 3 numerical characters.

58Floating rate of leg 2

The name of the floating rate index

‘EONA’ – EONIA

‘EONS’ – EONIA SWAP

‘EURI’ – EURIBOR

‘EUUS’ – EURODOLLAR

‘EUCH’ – EuroSwiss

‘GCFR’ – GCF REPO

‘ISDA’ – ISDAFIX

‘LIBI’ – LIBID

‘LIBO’ – LIBOR

‘MAAA’ – Muni AAA

‘PFAN’ – Pfandbriefe

‘TIBO’ – TIBOR

‘STBO’ – STIBOR

‘BBSW’ – BBSW

‘JIBA’ – JIBAR

‘BUBO’ – BUBOR

‘CDOR’ – CDOR

‘CIBO’ – CIBOR

‘MOSP’ – MOSPRIM

‘NIBO’ – NIBOR

‘PRBO’ – PRIBOR

‘TLBO’ – TELBOR

‘WIBO’ – WIBOR

‘TREA’ – Treasury

‘SWAP’ – SWAP

‘FUSW’ – Future SWAP

Or up to 25 alphanumerical characters if the reference rate is not included in the above list

59Floating rate reference period leg 2 – time period

Time period describing reference period, whereby the following abbreviations apply:

Y = Year

M = Month

W = Week

D = Day

60Floating rate reference period leg 2 – multiplier

Integer multiplier of the time period describing the reference period.

Up to 3 numerical characters.

Section 2g – Foreign ExchangeCurrency derivatives
61Delivery currency 2ISO 4217 Currency Code, 3 alphabetical character code
62Exchange rate 1

Up to 10 numerical digits including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

63Forward exchange rate

Up to 10 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

64Exchange rate basisTwo ISO 4217 currency codes separated by ‘/’. First currency code shall indicate the base currency, and the second currency code shall indicate the quote currency.
Section 2h – Commodities and emission allowancesCommodity and emission allowance derivatives
General
65Commodity base

AG = Agricultural

EN = Energy

FR = Freights

ME = Metals

IN = Index

EV = Environmental

EX = Exotic

OT = Other

66Commodity details
Agricultural

GO = Grains oilseeds

DA = Dairy

LI = Livestock

FO = Forestry

SO = Softs

SF = Seafood

OT = Other

Energy

OI = Oil

NG = Natural gas

CO = Coal

EL = Electricity

IE = Inter-energy

OT = Other

Freights

DR = Dry

WT = Wet

OT = Other

Metals

PR = Precious

NP = Non-precious

Environmental

WE = Weather

EM = Emissions

OT = Other

Energy
67Delivery point or zone

EIC code, 16 character alphanumeric code

Repeatable field.

68Interconnection PointEIC code, 16 character alphanumeric code
69Load type

BL = Base Load

PL = Peak Load

OP = Off-Peak

BH = Hour/Block Hours

SH = Shaped

GD = Gas Day

OT = Other

Repeatable section of fields 70 – 77
70Load delivery intervalshh:mmZ
71Delivery start date and timeISO 8601 date in the UTC time format YYYY-MM-DDThh:mm:ssZ
72Delivery end date and timeISO 8601 date in the UTC time format YYYY-MM-DDThh:mm:ssZ
73Duration

N = Minutes

H = Hour

D = Day

W = Week

M = Month

Q = Quarter

S = Season

Y = Annual

O = Other

74Days of the week

WD = Weekdays

WN = Weekend

MO = Monday

TU = Tuesday

WE = Wednesday

TH = Thursday

FR = Friday

SA = Saturday

SU = Sunday

Multiple values separated by ‘/’ are permitted

75Delivery capacity

Up to 20 numerical digits including decimals

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

76Quantity Unit

KW

KWh/h

KWh/d

MW

MWh/h

MWh/d

GW

GWh/h

GWh/d

Therm/d

KTherm/d

MTherm/d

cm/d

mcm/d

77Price/time interval quantities

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

Section 2i – OptionsContracts that contain an option
78Option type

P = Put

C = Call

O = where it cannot be determined whether it is a call or a put

79Option exercise style

A = American

B = Bermudan

E = European

S = Asian

More than one value is allowed

80Strike price (cap/floor rate)

Up to 20 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

The negative symbol, if populated, is not counted as a numerical character.

Where the strike price is reported in percent values, it should be expressed as percentage where 100 % is represented as ‘100’

81Strike price notation

U = Units

P = Percentage

Y = Yield

82Maturity date of the underlyingISO 8601 date in the format YYYY-MM-DD
Section 2j – Credit derivatives
83Seniority

SNDB = Senior, such as Senior Unsecured Debt (Corporate/Financial), Foreign Currency Sovereign Debt (Government),

SBOD = Subordinated, such as Subordinated or Lower Tier 2 Debt (Banks), Junior Subordinated or Upper Tier 2 Debt (Banks),

OTHR = Other, such as Preference Shares or Tier 1 Capital (Banks) or other credit derivatives

84Reference entity

ISO 3166 – 2 character country code

or

ISO 3166-2 – 2 character country code followed by dash ‘-’ and up to 3 alphanumeric character country subdivision code

or

ISO 17442 Legal Entity Identifier (LEI) 20 alphanumerical character code

85Frequency of payment

MNTH = Monthly

QURT = Quarterly

MIAN = Semi-annually

YEAR = Yearly

86The calculation basisNumerator/Denominator where both, Numerator and Denominator are numerical characters or alphabetic expression ‘Actual’, e.g. 30/360 or Actual/365
87SeriesInteger field up to 5 characters
88VersionInteger field up to 5 characters
89Index factor

Up to 10 numerical characters including decimals.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

90Tranche

T = Tranched

U = Untranched

91Attachment point

Up to 10 numerical characters including decimals expressed as a decimal fraction between 0 and 1.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

92Detachment point

Up to 10 numerical characters including decimals expressed as a decimal fraction between 0 and 1.

The decimal mark is not counted as a numerical character. If populated, it shall be represented by a dot.

Section 2k – Modifications to the contract
93Action type

N = New

M = Modify

E = Error

C = Early Termination

R = Correction

Z = Compression

V = Valuation update

P = Position component

94Level

T = Trade

P = Position

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