ESMA_QA_2794
Status: ✅ Answer Published
Link to ESMA Q&A tool: https://www.esma.europa.eu/publications-data/questions-answers/2794
Regulatory Context
Regulation : SFTR
Level 1 Regulation: Securities Financing Transactions Regulation (SFTR) Regulation (EU) 2015/2365- MDP
Level 2 Regulation: No information available
Level 3 Regulation: No information available
Topic: * SFTR Art. 4
Subject Matter: Updating the Loan Value and Security Price Fields following lifecycle events
Question
Submission Date: 03 March 2026
For securities lending and borrowing transactions, should Field 2.49 – ‘Security or Commodity Price’ and Field 2.56 – ‘Loan Value’ be updated and reported whenever mark-to-market adjustments are agreed between counterparties?
ESMA Answer
Answer Date: 03-03-2026
Yes, Field 2.49 – ‘Security or Commodity Price’ and Field 2.56 – ‘Loan Value’ should be updated whenever a lifecycle event occurs, including mark-to-market adjustments agreed between counterparties.
Under SFTR, ‘Cash Marks’ and ‘Fee Marks’ are considered as lifecycle events and must be reported using action type ‘MODI’. When counterparties adjust the loan value to reflect market price movements, the corresponding reports should be amended to reflect the updated values.
This is consistent with ESMA’s guidance in Table 6 of Section 4.10 (‘Mapping business events to action types and levels’) of the Guidelines on reporting under SFTR, which identifies cash marks and fee marks (events #22 and #23) as business events which allow a MODI report.
This document was automatically extracted from the ESMA EMIR Q&A database.