EMIR PTRR Exemption: ESMA’s Final Draft RTS for Clearing-Exempt Trades

On 20 October 2026 ESMA published its final report ESMA74-1049116226-981, which contains the draft regulatory technical standards that specify when transactions from post-trade risk reduction (PTRR) services qualify for the EMIR PTRR exemption from the clearing obligation under Article 4b of EMIR. The report records that ESMA submitted it to the European Commission on 9 October 2026. Article 4b(6) had set a submission deadline of 25 December 2025; ESMA’s March 2025 prioritisation letter to the Commission had already listed this RTS among the EMIR 3 deliverables to be delayed.

The exemption itself has applied since EMIR 3 took effect on 24 December 2024, without any RTS. A PTRR transaction escapes the clearing obligation only if the provider meets Article 4b(3) and (4), each participant meets Article 4b(3), and the provider’s MiFID competent authority has notified the provider to ESMA. If ESMA removes a provider from its list, transactions from that provider’s exercises are no longer exempt from the removal date. The draft RTS add the measurable detail: a three-part risk reduction test, a market risk neutrality standard anchored to participants’ tolerances, a defined output proposal, records kept for at least ten years, and an annual compliance confirmation to the provider’s supervisor.

Most of the new obligations sit with PTRR service providers, which Level 1 already requires to be MiFID investment firms. Counterparties that submit portfolios keep their own Level 1 conditions and their EMIR reporting duties, which the RTS leave unchanged, plus open field-population questions on fields 2.30 and 2.39 that the final report did not settle.

Related reading: EMIR Reporting Explained

Key dates for the EMIR PTRR exemption RTS

The two notification dates come from the version of ESMA’s provider list updated on 17 July 2025, the latest version found for this article. Article 4b(5) only requires ESMA to publish the list once a year, so a provider notified after the last update may not appear on it yet.

What Article 4b already requires, with or without the RTS

Article 4b(1) disapplies the clearing obligation in Article 4(1) for an OTC derivative “initiated and concluded as the result of an eligible” PTRR exercise. Article 4b(2) then sets two gates. The provider must meet paragraphs 3 and 4, and each participant must meet paragraph 3. Paragraph 3 describes the exercise itself. An eligible exercise must:

• be performed by an investment firm authorised under Article 7 of MiFID II that is independent of the counterparties to the contracts in the exercise;
• achieve a reduction in risk in each portfolio submitted;
• be accepted in full, so participants cannot pick which trades to execute;
• be open only to entities that initially submitted a portfolio;
• be market risk neutral and not contribute to price formation;
• take the form of compression, rebalancing or optimisation, or a combination, executed bilaterally or multilaterally.

Paragraph 4 lists the provider’s duties: follow pre-agreed rules and algorithms in prescheduled cycles, act in a reasonable, transparent and non-discriminatory way, keep participants from influencing the result, run regular compression where exercises create new PTRR transactions, keep complete records, make them available on request to the competent authority and ESMA, and monitor resulting transactions for misuse or circumvention of the clearing obligation “to the extent possible”.

Paragraph 5 adds a procedural gate. Before any transaction from a provider’s exercise can be exempt, the competent authority that authorised the provider must notify ESMA of the provider’s name and share its assessment of compliance. That authority confirms compliance to ESMA at least annually and must tell ESMA without undue delay when a provider no longer complies. ESMA then removes the provider from its list. The version updated on 17 July 2025 names two providers: TriOptima AB (Sweden, notified by Finansinspektionen, LEI 213800YD7WP4IMB52K89) and Quantile BV (Netherlands, notified by the AFM, LEI 213800ZR97OLR5C9FA84).

The participant’s position needs its own check: Article 4b(2)(b) makes the participant’s own compliance with paragraph 3 a separate condition. And Article 4b(1) opens with the words “without prejudice to risk-mitigation techniques under Article 11”. My reading is that a PTRR transaction that stays bilateral remains subject to confirmation, reconciliation and margin wherever those Article 11 techniques already apply to the two counterparties. Our note on the EMIR bilateral margin RTS amendments covers that framework.

ESMA’s cost-benefit analysis uses Level 1 without RTS as its baseline: participants and competent authorities relying directly on Article 4b, with lower short-term implementation costs but less legal certainty and a risk of divergent approaches to concepts such as market risk neutrality, risk reduction and mixed portfolios.

Compression, rebalancing and basis risk optimisation in Articles 1 to 3

Chapter I of the draft describes the three service types that EMIR 3 names. Recital 2 explains that the RTS use “basis risk optimisation” for the Level 1 term “optimisation”.

Two respondents asked ESMA to delete the “no existing trade is terminated or replaced” wording from Articles 2 and 3, because both services sometimes terminate trades from earlier runs to avoid unnecessary notional. ESMA kept the wording for two reasons. The descriptions are meant to capture each service’s distinctive objective and main mechanism. And Article 2 is taken from the definition of “Portfolio Rebalancing/Margin management” in the EMIR reporting standard, Commission Delegated Regulation (EU) 2022/1855; changing it would create a second definition of rebalancing within EMIR.

A rebalancing run that also tears up offsetting trades from earlier runs can still qualify. ESMA describes those terminations as ancillary, purely administrative housekeeping, and confirms that a rebalancing or basis risk optimisation exercise can be combined with a compression to clean up the book. Where an exercise shows all the identifying features of more than one type, it can benefit from the exemption as a combination under Article 4b(3)(g).

The RTS stop at these three types. Respondents identified no other PTRR service that needed express coverage. ESMA’s view is that technical standards specifying Article 4b cannot be open-ended, so its willingness to look at new service types later appears in the report and not in the draft text.

The three-part risk test and market risk neutrality

Article 4(1) departs from a suggestion in ESMA’s 2020 report on PTRR services to limit compression to uncleared portfolios: exercises can include portfolios that mix cleared and uncleared transactions, provided the exercise achieves risk reduction. Article 4(2) defines risk reduction for Article 4b(3)(b) as three cumulative conditions:

• the overall risk of each submitted portfolio falls;
• specific risk types that contribute to overall risk rise only within the tolerances set by participants “specifically for each exercise”;
• the aggregate net uncleared risk does not increase in any submitted portfolio.

The third condition is ESMA’s answer to the circumvention scenario it described in the consultation. Trades outside the clearing obligation, for example with non-standard calendars, could be replaced with standard swaps of a class subject to clearing. Those swaps would then stay bilateral under the exemption, so the firm keeps its exposure without clearing it.

Recital 3 defines uncleared risk as the risk from bilateral transactions not cleared via a CCP. On method, the final report says that comparing net uncleared risk before and after the exercise is enough. Both the output proposal (Article 12(1)(f)) and the provider’s records (Article 15(d)) must show the result.

The tolerance wording matters for participants. Article 4(2)(b) refers to tolerances set specifically for each exercise, and Article 11(b) requires the provider to collect them before running the algorithm. On my reading, a standing tolerance profile can still be used, but it has to be confirmed as the input for each run.

Article 5(1) treats an exercise as market risk neutral when the market risk of all submitted portfolios is the same before and after, or within the participants’ tolerances. Article 5(2) requires the provider to ensure that tolerances are minimal and do not significantly affect the overall market risk exposure of the submitted portfolios. The final text added “submitted” after two respondents pointed out that providers cannot see a firm’s whole book.

The consultation framed Article 5(2) as a duty on providers to keep users’ tolerances within a range that broadly ensures neutrality and to reject excessive ones, even though the provision sets no numeric cap. ESMA declined to prescribe a metric. A provider may express risk in DV01, but ESMA prefers not to mandate any unit before the RTS enter into force, and says it stands ready to consider guidance on metrics if consistency problems appear afterwards.

Operating conditions for PTRR service providers (Articles 6 to 14)

Chapter III carries most of the implementation work. The table maps each article to its core requirement as drafted.

Article 11(b) is more granular than the table can show. The provider must require each participant to specify its risk tolerances, “including the potential exclusion of PTRR transactions with certain counterparties” and limits on counterparty risk, market risk and cash payment tolerances. Article 12(1) then lists what each participant must receive after the algorithm runs: the counterparties included, the change in notional, the change in counterparty risk, a breakdown of how different risks fall, how compliance with each tolerance was ensured, and how the output avoids any increase in aggregate net uncleared risk.

One wording change in Article 12(2) affects workflow documents. The consultation draft said the provider “shall only validate” the output once all participants agreed. A respondent asked what “validate” meant. ESMA explained that it means confirming that all participants accepted and that the trades can be performed. It does not mean performing them, because participants usually do that, and it does not fix when the exercise becomes legally binding, which the parties may tie to another moment.

The final text now says the provider “shall notify” participants once all have accepted in full, in line with the process in the service agreement. The legally binding moment belongs in the Article 10 agreement.

Two pushbacks failed. Respondents argued that Articles 6, 13 and 14 duplicate obligations MiFID investment firms already carry. ESMA replied that MiFID’s conflicts rules concern investment and ancillary services, which differ from PTRR services.

A second pushback proposed an annual attestation in place of Article 14’s ongoing checks, on the basis that meeting the ex-ante conditions rules out circumvention. ESMA kept the checks, describing them as an extra safeguard on the algorithm’s output even when the algorithm is set correctly. Recital 12 adds that the governance arrangement should avoid key-man dependency risk.

Records, the PTRR ID and ten-year retention

Article 4b(4)(d) already requires records of the transactions entered into the exercise, the transactions resulting from it, and the overall change in risk of each portfolio. Article 15 of the draft adds four items to those records:

• the PTRR ID referred to in Article 7 of Delegated Regulation (EU) 2022/1855;
• information showing the result is market risk neutral;
• a breakdown of how each risk type was reduced, or kept within tolerances, in each submitted portfolio;
• information showing no increase in aggregate net uncleared risk in any participant’s portfolio.

Article 16 requires the records to be kept for at least ten years after each exercise. Recital 15 aligns this with Article 80(3) of EMIR, which sets trade repositories’ retention period. ESMA does not prescribe a storage format, and it encourages providers to use the Exercise Performance Report they already produce, provided it contains the required content and is available to competent authorities and ESMA without undue delay on request.

Participants receive their own copy. Article 9(3) requires the provider to send each participant, promptly and in a durable medium, information on the executed transactions, including the Article 15 content, and to retain it and provide it again on request for the same retention period. Recital 8 gives the reason: participants may need to retrieve it when their own competent authority asks, as part of monitoring the exemption under Article 4 of EMIR.

The PTRR ID links the two sides. In the EMIR reporting XML documentation, field 2.5 (PTRR ID) is defined as an identifier generated by the PTRR service provider or the CCP providing the service to connect all derivatives entering and resulting from a PTRR event. ESMA’s stated aim in Article 15(a) is reconciliation between what counterparties report and what the provider keeps. On my reading, a mismatch between a counterparty’s reported PTRR IDs and the provider’s records becomes detectable whenever a supervisor compares the two.

EMIR reporting of exempt PTRR transactions

Respondents asked how to populate the “Clearing obligation” field for PTRR transactions that benefit from the exemption. ESMA’s answer, in paragraph 105 of the final report, is that the RTS do not change the rules in Delegated Regulation (EU) 2022/1855. Exempt PTRR transactions are reported with the clearing field showing that the derivative was not cleared, and the additional clearing-detail fields stay empty. A footnote points to fields 7 and 13 (clearing threshold) and 16 (clearing member) in Table 1, plus the Section 2f clearing fields and field 152 (event type) in Table 2.

For a reporting team, the relevant Table 2 fields line up as follows. Field names and definitions are taken from ESMA’s EMIR reporting XML documentation; the right-hand column separates ESMA’s stated position from my reading.

Two gaps remain. Field 2.30 is defined by class and counterparty status at execution, and it makes no reference to transaction-level exemptions. ESMA’s answer covered the “cleared” flag but did not say what goes in 2.30.

Field 2.39 was written before EMIR 3. Its codes cover compression without a provider (PWOS), compression with a provider or CCP (PWAS), portfolio rebalancing and margin management (PRBM), and “Other Portfolio PTRR services” (OTHR), defined as services that qualify as neither compression nor rebalancing. Basis risk optimisation appears to meet that definition. The field takes a single value, and neither ESMA document says which code a combined compression-and-rebalancing run should carry. Firms tracking wider changes to the EMIR data set can follow our article on ESMA’s transaction reporting simplification across EMIR, MiFIR and SFTR.

Annual confirmation and the monitoring loop in Article 17

Chapter IV covers the Article 4b(6)(f) mandate on monitoring the exemption. Under Article 17, the competent authority of each provider assesses compliance with Article 4b(3) and (4), and the provider confirms its compliance to that authority, annually or when the authority asks. The confirmation comes with a report containing:

• changes to the conflicts of interest policy, plus the conflicts that arose during the year and how they were managed;
• any changes to the provider’s rules and any material changes to the methods and algorithms in Article 8, or to the methodologies used to develop and test them;
• changes to the governance arrangement in Article 13;
• the internal reports required by Article 14(4) to (6).

The second item changed after consultation. Two respondents asked that only material changes be reported, because algorithms are fine-tuned continuously. ESMA agreed for methods and algorithms but not for rules: any change to the provider’s rules is always reportable, while changes to methods and algorithms are reportable only if material. On my reading, a provider therefore needs a documented materiality test for algorithm changes.

Article 17(6) operates between annual cycles. Whenever there is a material change, or a planned material change, in policies, rules, methods, algorithms or governance, or a case of non-compliance with Article 4b(3) or (4), the provider must notify its competent authority without undue delay. The words “planned material change” suggest that notification belongs in the change-management process at the planning stage, before deployment. The draft sets no calendar date for the annual confirmation. Recital 16 says the authority’s assessment happens at least annually or when the authority considers it necessary, for example when participants’ supervisors share information that points to circumvention.

Participants’ supervisors keep their own role. A footnote in the final report says they retain their role in monitoring potential circumvention under Article 4 of EMIR and are expected to exchange information with providers’ authorities when misuse is suspected.

MiFIR Article 31 runs on a separate track

MiFIR Article 31 provides a separate exemption for OTC derivative transactions formed and established as a result of PTRR services, so eligibility is tested against Article 31 MiFIR and the Article 16a conditions in Delegated Regulation (EU) 2017/567, not assumed from EMIR Article 4b eligibility. Since the MiFIR Review, Regulation (EU) 2024/791, Article 31(1) MiFIR disapplies the transparency requirements in Articles 8a, 10 and 21, the trading obligation in Article 28 and best execution under Article 27 of MiFID II for OTC derivative transactions “formed and established as a result of” PTRR services. Under Article 31(3), providers keep records of those transactions that are “not already recorded or reported” under EMIR. Article 31(4) empowers the Commission to specify (a) the eligible PTRR services and (b) the transactions to be recorded.

Point (a) has been delivered. Commission Delegated Regulation (EU) 2026/482 of 24 November 2025, published in the Official Journal on 27 February 2026, amends Delegated Regulation (EU) 2017/567. The final report treats it as the delegated act under point (a) and names compression, rebalancing and basis risk optimisation as eligible services. The consultation paper, issued before that publication, quotes the Article 16a(1) conditions in points (a) to (e) of the delegated act: a third-party provider using non-discretionary rules set in advance, acceptance in full, risk reduction in each portfolio, market risk neutrality within tolerances, and no contribution to price formation.

Point (b) had not been adopted when the final report was written. Section 5 of the report is a recommendation to the Commission: records should at least list the derivatives submitted, those changed or terminated, and those added or used as replacements, and providers should be allowed to rely on the Exercise Proposal or Exercise Performance Report if those documents show market risk neutrality, the risk reduction objective and the non-price-forming nature of the trades.

MiFIR transaction reporting is a separate question again. The consultation paper notes that Article 2(5)(f) of Delegated Regulation (EU) 2017/590 excludes transactions resulting from compression from Article 26 MiFIR reporting. Neither ESMA document says that exclusion now covers rebalancing or basis risk optimisation, so the current text of that regulation is the place to check before treating those trades as outside Article 26 reporting. Our MiFIR transaction reporting guide covers how Article 26 works.

What changed between the February consultation and the final draft

ESMA describes its adjustments as marginal. The table compares the provisions that did change.

The list of requests ESMA declined is longer. The “no termination or replacement” wording in Articles 2 and 3 stays. No mandatory risk metric was added, although one respondent asked for DV01. The Article 14 checks were not replaced with an annual attestation.

The second subparagraph of Article 9(2) was not deleted, because ESMA treats it as a safeguard if the provider’s own controls miss a tolerance breach. ESMA also refused to add “to the extent possible” to the Article 11 eligibility check, on the basis that “on the basis of the information provided” already limits the provider’s responsibility. The final draft also contains no tolerance criteria and no limits on portfolio composition; no respondent proposed the former, and a majority opposed the latter.

Drafting points to check against the adopted text

Teams mapping controls to article numbers should note four drafting slips in Annex VI that may be corrected before adoption. The cover line reads “Commission Implementing Regulation”. Article 4b(6), however, delegates power to adopt regulatory technical standards under Articles 10 to 14 of the ESMA Regulation, and recital 61 of EMIR 3 provides that the Commission should adopt these RTS by means of delegated acts under Article 290 TFEU.

Recital 13 locates the circumvention criterion in “point c) of Article 5”, but the operative text is Article 4(2)(c), repeated in Article 14(3). Article 14(2) refers to neutrality and risk reduction “as laid down in Article 4 and 5 of this Regulation respectively”, which pairs neutrality with Article 4 and risk reduction with Article 5, the reverse of the substantive articles. The chapter numbering also jumps from Chapter IV to Chapter VI. The substance is unaffected, and the Official Journal text will be the version to map against.

Frequently Asked Questions

Our provider says it has been notified, but it is not on ESMA’s published list. Can we rely on the exemption for its runs?

Article 4b(5) makes the competent authority’s notification to ESMA the condition, and ESMA publishes the list only on a yearly basis, so the published list can lag a notification. The exemption turns on the notification having taken place. On my reading, the evidence worth keeping with the exercise records is the provider’s written confirmation of its notification date and notifying authority.

What happens to trades already executed if ESMA removes our provider from the list?

Article 4b(5) says that from the date of removal, PTRR transactions from exercises performed by that provider are no longer exempt from the clearing obligation. The provision is framed from the removal date onwards and does not expressly say how transactions concluded before removal are treated. That is a legal question for counsel, and the removal date is the fact to record.

Our portfolio got no risk reduction in a run and we dropped out. Does the whole exercise then fail the “each portfolio” test?

The final report says that where a participant drops out because it receives no risk reduction in the run, its portfolios are not taken into account when assessing whether risk reduction occurred in all portfolios. How acceptance and drop-out work operationally is governed by the service agreement process that Article 12(2) refers to.

Our group holds a stake in the PTRR provider. Does that rule out participation?

The draft sets no ownership threshold. Level 1 requires the provider to be independent of the counterparties, and the RTS handle this through Article 6: a dedicated conflicts section and records of when conflicts may arise. Recital 4 uses a participant in the same group as the provider as its example of a conflict that needs attention. Recital 5 treats disclosure as a last resort after organisational arrangements. One respondent pointed out that providers can sit in groups that include CCPs or have participant investors, and ESMA did not add a structural ban.

Can we stop a rebalancing run from loading new trades onto specific counterparties?

Yes, through tolerances. Article 11(b) requires the provider to ask each participant for risk tolerances that include the potential exclusion of PTRR transactions with certain counterparties, along with counterparty risk, market risk and cash payment limits.

Does the EU exemption cover our UK EMIR clearing obligation?

Article 4b is a provision of EU EMIR, Regulation (EU) No 648/2012 as amended by Regulation (EU) 2024/2987. UK EMIR is separate assimilated UK law. The final report notes the FCA’s April 2025 policy statement PS25/2 on the derivatives trading obligation and PTRR services. UK-facing trades need to be assessed under the UK rules.

Do the RTS conditions apply to runs executed before entry into force?

Draft Article 18 provides for entry into force on the twentieth day after Official Journal publication, with no transitional provision. Until then, providers and participants rely on Article 4b directly. ESMA says the draft builds on current practice and on the assessments competent authorities already carried out for the listed providers. On my reading, that points to documentation and evidence as the main work for listed providers; the draft still contains no grace period after entry into force.

Related Articles

• EMIR Reporting Explained: the EMIR Article 9 reporting framework, field structure and trade repository workflow that PTRR transactions flow through.
• EMIR 3 Clearing Obligation, Thresholds and Active Account: how EMIR 3 reshaped the clearing obligation that the PTRR exemption carves into.
• EMIR Bilateral Margin RTS Amendments: the Article 11 risk-mitigation and margin rules that continue to frame uncleared trades.
• EMIR 3 Clearing Thresholds: Uncleared and Aggregate RTS: ESMA’s work on clearing thresholds for uncleared and aggregate positions under EMIR 3.
• MiFIR Transaction Reporting: Article 26 MiFIR reporting, relevant when deciding how PTRR trades are treated outside EMIR.

Key Takeaways

• Providers: assign an owner and an evidence artefact to each of draft Articles 6 to 17 now. Draft Article 18 provides for entry into force on the twentieth day after OJ publication, with no phase-in, if the Commission adopts the text as submitted.
• Counterparties: before relying on a provider’s runs, file evidence of its Article 4b(5) notification and the ESMA list version checked, and record any removal date.
• Tolerance governance: confirm tolerances, including counterparty exclusions, as an input to each exercise; a stale standing profile is a weak point under Article 4(2)(b).
• Records: secure the Article 9(3) durable-medium copy for each run and keep a retrieval route for ten years; recital 8 anticipates requests from participants’ own supervisors.
• Reporting: decide internally, with your documented rationale, how fields 2.30 and 2.39 will be populated for exempt runs; the final report settles only the “cleared” flag and the empty clearing-detail fields.
• Change management (providers): any rules change and any material algorithm change goes into the annual report, and planned material changes are covered by the Article 17(6) notification duty, so schedule that notice at the planning stage.
• MiFIR: the delegated act on which transactions must be recorded under Article 31(3) is still pending; ESMA has only recommended that existing exercise documents be accepted.

Sources and References

• ESMA, Final Report: Regulatory Standards on the requirements for Post-Trade Risk Reduction services for the purpose of the clearing obligation exemption under EMIR, ESMA74-1049116226-981 (20 October 2026): Final Report (PDF)
• ESMA news, “ESMA specifies requirements to facilitate safe use of post-trade risk reduction services” (20 October 2026): ESMA news item
• ESMA, Consultation Paper on the PTRR services RTS, ESMA74-1049116226-877 (26 February 2026): Consultation Paper (PDF)
• ESMA news, “ESMA consults on post-trade risk reduction services under EMIR 3” (26 February 2026): ESMA news item
• ESMA, List of post-trade risk reduction service providers notified to ESMA, ESMA74-1049116225-664 (updated 17 July 2025): Provider list (PDF)
• ESMA, letter from the Chair on prioritisation of 2025 ESMA deliverables, ESMA22-50751485-1598 (3 March 2025): Prioritisation letter (PDF)
• Regulation (EU) 2024/2987 (EMIR 3), OJ L, 4.12.2024: EUR-Lex
• Regulation (EU) No 648/2012 (EMIR): EUR-Lex
• ESMA Interactive Single Rulebook, EMIR Article 4b: ESMA rulebook page
• Commission Delegated Regulation (EU) 2022/1855 (EMIR reporting RTS): EUR-Lex
• ESMA, EMIR Refit ISO 20022 reporting message documentation (auth.030.001.03), v1.0.0: ESMA download (ZIP)
• Regulation (EU) 2024/791 (MiFIR Review): EUR-Lex
• Regulation (EU) No 600/2014 (MiFIR), Articles 26 and 31: EUR-Lex
• Directive 2014/65/EU (MiFID II), Article 7: EUR-Lex
• Commission Implementing Regulation (EU) 2022/1860 (EMIR reporting ITS, permitted values for field 2.39): EUR-Lex
• Commission Delegated Regulation (EU) 2026/482 amending Delegated Regulation (EU) 2017/567, as linked in the final report: EUR-Lex
• Commission Delegated Regulation (EU) 2017/590 (MiFIR transaction reporting RTS): EUR-Lex
• Commission Delegated Regulation (EU) 2017/565 (MiFID II organisational requirements, Article 34 conflicts policy): EUR-Lex
• Regulation (EU) No 1095/2010 (ESMA Regulation), Articles 10 to 14: EUR-Lex
• FCA, PS25/2: Policy Statement on the derivatives trading obligation and post-trade risk reduction services: FCA policy statement

Next checkpoint: the Commission’s adoption decision

The draft RTS now sit with the Commission, which has three months from its receipt of them to decide whether to adopt them under Article 10 of the ESMA Regulation. ESMA’s final report records submission on 9 October 2026; on my count, assuming receipt that day, the decision window runs to early January 2027, followed by scrutiny and Official Journal publication, with entry into force twenty days later. Providers can use that window to build the Article 17 report pack and the ten-year record set behind Article 15. Counterparties can load the LEIs from ESMA’s current provider list into their field 2.40 reference data and record their decision on how fields 2.30 and 2.39 are populated for exempt PTRR runs.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.