Error correction form ISDA best practice

Control Category

Point of Discovery

Daily Exception Management

SDR NACK received and cannot be resolved within 7 business days of receipt

NACK receipt

Open Swaps Report Verification

Error identified during the 30-calendar day Verification Process using SDR provided 'Open Swaps Report"

Start of verification process

Other Controls e.g., Reconciliation, Quality Assurance, Internal Testing etc.

Error is considered discovered from the moment of error confirmation

Upon internal confirmation of Error

Communication from Non-reporting Counterparty (NRP)

Error(s) notification received from an NRP and is confirmed as being an Error by the RP

Receipt of Error Notification

#

Required Data

ISDA 2022 subWG discussion/decisions

Example Values

1(a)

Date of notification

Align with date convention provided in section 1.2.1(6) of Technical Specification data element reporting specifications for "Format" YYYY-MM-DD

2022-05-27

1(b)

Name(s) of entit(ies)y making the notification

Full Legal Name(s). This can be more than one.

Bank ABC
or
Bank ABC; Bank 123

1(c)

Legal Entity Identifier(s) (“LEIs”) of Notifying Entity

LEI(s). This can be more than one.

LEI….Bank A
or
LEI….Bank ABC; LEI…Bank 123

1(d)

Contact person(s) regarding notification

Name of contact person(s). This can be more than one depending on individual firms' preference

Frank Dodd
or
Frank Dodd; Jane Doe

1(e)

Contact person(s) email and phone number

Email & Phone number of contact person(s). This can be more than one depending on individual firms' preference

fdodd@bankabc.com, +12345678910
or
fdodd@bankabc.com, +12345678910; jdoe@bankabc, +12345671089

2

Statement clarifying whether the notification concerns error(s) relating to:

Restate applicable number and statement

(i) swap data previously reported to an SDR

2(i)

swap data previously reported to a swap data repository (“SDR”);

2(ii)

swap data that was not previously reported to an SDR; or

2(iii)

both swap data previously reported and swap data not previously reported to an SDR

3

If the notification concerns error(s) relating to data previously reported to an SDR, a listing of the Unique Swap Identifiers and/or Unique Transaction Identifiers (“USIs” and/or “UTIs”) associated with swap reports that are representative of the error(s)

Where issue is identified under question 2 as (i) “swap data previously reported to an SDR” or (iii) “both swap data previously reported and swap data not previously reported to an SDR”, populate one/many USIs/UTIs that relate to the Error
OR
Where issue is identified under question 2 as (ii) i.e. no USIs/UTIs value is available, populate ‘No representative USIs/UTIs available'

UTI1234….XZY
or
Collateral Portfolio Code
or
"No representative USIs/UTIs available"

4

Swap asset class(es) to which the error(s) pertain

Until UPI is implemented, per Appendix 1 of P45/Technical Specifications use CR = credit, IR = rates, FX = foreign exchange, EQ = equities and CO = commodities

CR
or
CR; IR
or
CR; IR; FX; EQ; CO

5

SDR(s) to which the swap data was/should have been reported

Use full legal name of SDR

DTCC Data Repository (U.S.) LLC

6

Other parties, if any, that the Notifying Entity has alerted to the error(s) (e.g., SDR(s), National Futures Association, swap counterparties, etc.)

If any notification of the error has taken place report full legal name of that party. If no notification has taken place populate with 'None'

None
or
Full Legal Name of SEF; National Futures Association; Full Legal Name of Counterparty

7(a)

Number of transactions impacted by the error(s)

Provide the number of related swaps based on the control process where the error was identified
or
Alternatively provide 'Not known in the initial assessment'

# of USIs/UTIs flagged by control
or
“Not known in the initial assessment”

7(b)

Number of swap reports impacted by the error(s)

Provide what Swap
Reports (messages) were
impacted by the errors.
For example if the response
to 7(a) is 3 UTIs/USIs, and  2 reports are
impacted (e.g. P43 and
P45) persisting 30 days (i.e. 30
reportable events), then 7(b) =
180;
Error impacting 1 UTI/USI
persisting through 10
valuation events = 10.

‘Provide number’
or
"Not known in the initial assessment"

7(c)

Time period during which error(s) occurred (“Relevant Time Period”)

To be populated with the date that the error was introduced using the date convention provided in section 1.2.1(6) of Technical Specification for "Format" YYYY-MM-DD.

Alternatively provide 'Not known in the initial assessment'

2022-05-27
or
"Not known in the initial assessment"

7(d)

The percent of the Notifying Entity’s reportable transactions impacted during the Relevant Time Period (i.e., (number of transactions impacted by the error(s) / number of transactions reported by Notifying Entity during the Relevant Time Period) * 100)

Baseline based on the total number of swaps reported at the point in time that the error in the associated control was run. E.g., total number of swaps in the Open Swap Report the run date

Alternatively provide 'Not known in the initial assessment'

10%
or
Not known in the initial assessment

7(e)

The percent of the Notifying Entity’s reportable transactions impacted during the Relevant Time Period for each impacted asset class (e.g., (Number of interest rate swap (“IRS”) transactions impacted by the error(s) / number of IRS transactions reported by Notifying Entity during the Relevant Time Period) * 100)

Baseline based on the total number of swaps reported within the impacted Asset Class(es) at the point in time that associated control was run. E.g., total number of swaps within the impacted Asset Class(es) in the Open Swap Report on its run date.

Alternatively provide 'Not known in the initial assessment'

5%
or
"Not known in the initial assessment"

8

Date the Notifying Entity discovered the error(s)

Provide date in line the Control that discovered the error: For Open Swap Verification provide date the results were made available; For SDR NACK provide the date the NACK was received, For NRP Communication provide date the notification was received; For all other internal control processes provide date the error was confirmed

YYYY-MM-DD

9

Description of how the Notifying Entity discovered the error(s)

Confirm what Control process identified the Error

Open Swaps Report
or
SDR NACK
or
NRP Communication
or
Other Control Process

10

Brief narrative description of the error(s)

Level of detail up to discretion of notifying firm

Level of detail up to discretion of notifying firm

11

Clarification regarding whether the issues underling the error(s) are still producing new error(s) as of the date of the notification

Yes/No confirmation that the Error identified been remediated on a go-forward basis from point of notification i.e., the error is only applicable to swaps reported before the notification date.

Yes
or
No

12(a)

Any initial or other remediation plan, including the estimated date(s) when the error(s) will be corrected

 Provide remediation plan (including remediation date) details if available

Level of remediation plan detail up to discretion of notifying firm (using 'YYYY-MM-DD' format for any date communication)
or
Not yet known in initial assessment

12(b)

If no initial or other remediation plan exists, the date when the Notifying Entity expects to have a remediation plan to correct the error(s)

Required to be populated if 12(a) is ‘Not yet known in initial assessment’ 

N/A if estimated date for error correction is provided in response to 12(a)
or
YYYY-MM-DD

13

An indication regarding whether the Notifying Entity has reviewed its swaps reporting processes to identify other potential reporting issues similar to that underlying the error(s)

Level of detail up to discretion of notifying firm
or
Not able to determine in the initial assessment

14

Clarification regarding whether the error(s) impacted the Notifying Entity’s reporting obligations under Part 45, Part 43, or both Parts 45 and 43

Provide details of impact of Error to Part 43, Part 45 or both.

Part 43
or
Part 45
or
Part 43 and Part 45

Rule section

Rule Requirement (sub)header

Rule requirement Description

17 CFR 43.3 (e)

Method and timing for real-time public reporting (Correction of errors)

Correction of errors -

17 CFR 43.3 (e)(1)

Method and timing for real-time public reporting (Correction of errors)

Swap execution facilities, designated contract markets, and reporting counterparties. Any swap execution facility, designated contract market, or reporting counterparty that by any means becomes aware of any error relating to swap transaction and pricing data that it was required to report under this part shall correct the error. To correct an error, the swap execution facility, designated contract market, or reporting counterparty shall submit complete and accurate swap transaction and pricing data to the swap data repository that maintains the swap transaction and pricing data for the relevant swap, or completely and accurately report swap transaction and pricing data for a swap that was not previously reported to a swap data repository as required under this part, as applicable. Except as otherwise provided in this section, the requirement to correct any error applies regardless of the state of the swap that is the subject of the swap transaction and pricing data, including a swap that has terminated, matured, or otherwise is no longer considered to be an open swap.

17 CFR 43.3 (e)(1)(i)

Method and timing for real-time public reporting (Correction of errors)

Timing requirement for correcting errors. The swap execution facility, designated contract market, or reporting counterparty shall correct any error as soon as technologically practicable after discovery of the error. In all cases, errors shall be corrected within seven business days after discovery. Any error that a reporting counterparty discovers or could have discovered during the verification process required under § 45.14(b) of this chapter is considered discovered for the purposes of this section as of the moment the reporting counterparty began the verification process during which the error was first discovered or discoverable.

17 CFR 43.3 (e)(1)(ii)

Method and timing for real-time public reporting (Correction of errors)

Notification of failure to timely correct. If the swap execution facility, designated contract market, or reporting counterparty will, for any reason, fail to timely correct an error, the swap execution facility, designated contract market, or reporting counterparty shall notify the Director of the Division of Market Oversight, or such other employee or employees of the Commission as the Director may designate from time to time. The notification shall be in the form and manner, and according to the instructions, specified by the Director of the Division of Market Oversight, or such other employee or employees of the Commission as the Director may designate from time to time. Unless otherwise instructed by the Director of the Division of Market Oversight, or such other employee or employees of the Commission as the Director may designate from time to time, the notification shall include an initial assessment of the scope of the error or errors that were discovered, and shall include any initial remediation plan for correcting the error or errors, if an initial remediation plan exists. This notification shall be made within 12 hours of the swap execution facility's, designated contract market's, or reporting counterparty's determination that it will fail to timely correct the error.

17 CFR 43.3 (e)(1)(iii)

Method and timing for real-time public reporting (Correction of errors)

Form and manner for error correction. In order to satisfy the requirements of this section, a swap execution facility, designated contract market, or reporting counterparty shall conform to a swap data repository's policies and procedures created pursuant to § 49.10 of this chapter for correction of errors.

17 CFR 43.3 (e)(2)

Method and timing for real-time public reporting (Correction of errors)

Non-reporting counterparties. Any non-reporting counterparty that by any means becomes aware of any error in the swap transaction and pricing data for a swap to which it is the non-reporting counterparty, shall notify the reporting counterparty for the swap of the error as soon as technologically practicable after discovery, but not later than three business days following discovery of the error. If the non-reporting counterparty does not know the identity of the reporting counterparty, the non-reporting counterparty shall notify the swap execution facility or designated contract market where the swap was executed of the error as soon as technologically practicable after discovery, but no later than three business days following the discovery. Such notice from the non-reporting counterparty to the swap execution facility, designated contract market, or reporting counterparty constitutes discovery under this section.

17 CFR 43.3 (e)(3)

Method and timing for real-time public reporting (Correction of errors)

Exception. The requirements to correct errors set forth in paragraph (e) of this section only apply to errors in swap transaction and pricing data relating to swaps for which the record retention period under § 45.2 of this chapter has not expired as of the time the error is discovered. Errors in swap transaction and pricing data relating to swaps for which the record retention periods under § 45.2 of this chapter have expired at the time that the errors are discovered are not subject to the requirements to correct errors set forth in paragraph (e) of this section.

17 CFR 43.3 (e)(4)

Method and timing for real-time public reporting (Correction of errors)

Error defined -

17 CFR 43.3 (e)(4)(i)

Method and timing for real-time public reporting (Correction of errors)

Errors. For the purposes of this part, there is an error when swap transaction and pricing data is not completely and accurately reported. This includes, but is not limited to, the following circumstances:

17 CFR 43.3 (e)(4)(i)(A)

Method and timing for real-time public reporting (Correction of errors)

Any of the swap transaction and pricing data for a swap reported to a swap data repository is incorrect or any of the swap transaction and pricing data that is maintained by a swap data repository differs from any of the relevant swap transaction and pricing data contained in the books and records of a party to the swap.

17 CFR 43.3 (e)(4)(i)(B)

Method and timing for real-time public reporting (Correction of errors)

Any of the swap transaction and pricing data for a swap that is required to be reported to a swap data repository or to be maintained by a swap data repository is not reported to a swap data repository or is not maintained by the swap data repository as required by this part.

17 CFR 43.3 (e)(4)(i)(C)

Method and timing for real-time public reporting (Correction of errors)

None of the swap transaction and pricing data for a swap that is required to be reported to a swap data repository or to be maintained by a swap data repository is reported to a swap data repository or is maintained by a swap data repository.

17 CFR 43.3 (e)(4)(i)(D)

Method and timing for real-time public reporting (Correction of errors)

Any of the swap transaction and pricing data for a swap that is no longer an open swap is maintained by the swap data repository as if the swap is still an open swap.

17 CFR 43.3 (e)(4)(ii)

Method and timing for real-time public reporting (Correction of errors)

Presumption. For the purposes of this section, there is a presumption that an error exists if the swap data or the swap transaction and pricing data that is maintained and disseminated by an SDR for a swap is not complete and accurate. This includes, but is not limited to, the swap data that the SDR makes available to the reporting counterparty for verification under § 49.11 of this chapter.

17 CFR 45.14

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Correction of errors

17 CFR 45.14(a)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Correction of errors

17 CFR 45.14(a)(1)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Swap execution facilities, designated contract markets, and reporting counterparties. Any swap execution facility, designated contract market, or reporting counterparty that by any means becomes aware of any error relating to swap data that it was required to report under this part shall correct the error. To correct an error, the swap execution facility, designated contract market, or reporting counterparty shall submit complete and accurate swap data to the swap data repository that maintains the swap data for the relevant swap, or completely and accurately report swap data for a swap that was not previously reported to a swap data repository as required under this part, as applicable. Except as otherwise provided in this section, the requirement to correct any error applies regardless of the state of the swap that is the subject of the swap data, including a swap that has terminated, matured, or otherwise is no longer considered to be an open swap.

17 CFR 45.14(a)(1)(i)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Timing requirement for correcting errors. The swap execution facility, designated contract market, or reporting counterparty shall correct any error as soon as technologically practicable after discovery of the error. In all cases, errors shall be corrected within seven business days after discovery. Any error that a reporting counterparty discovers or could have discovered during the verification process required under paragraph (b) of this section is considered discovered for the purposes of this section as of the moment the reporting counterparty began the verification process during which the error was first discovered or discoverable.

17 CFR 45.14(a)(1)(ii)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Notification of failure to timely correct. If the swap execution facility, designated contract market, or reporting counterparty will, for any reason, fail to timely correct an error, the swap execution facility, designated contract market, or reporting counterparty shall notify the Director of the Division of Market Oversight, or such other employee or employees of the Commission as the Director may designate from time to time. The notification shall be in the form and manner, and according to the instructions, specified by the Director of the Division of Market Oversight, or such other employee or employees of the Commission as the Director may designate from time to time. Unless otherwise instructed by the Director of the Division of Market Oversight, or such other employee or employees of the Commission as the Director may designate from time to time, the notification shall include an initial assessment of the scope of the error or errors that were discovered, and shall include any initial remediation plan for correcting the error or errors, if an initial remediation plan exists. This notification shall be made within 12 hours of the swap execution facility's, designated contract market's, or reporting counterparty's determination that it will fail to timely correct the error.

17 CFR 45.14(a)(1)(iii)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Form and manner for error correction. In order to satisfy the requirements of this section, a swap execution facility, designated contract market, or reporting counterparty shall conform to a swap data repository's policies and procedures created pursuant to § 49.10 of this chapter for correction of errors.

17 CFR 45.14(a)(2)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Non-reporting counterparties. Any non-reporting counterparty that by any means becomes aware of any error in the swap data for a swap to which it is the non-reporting counterparty, shall notify the reporting counterparty for the swap of the error as soon as technologically practicable after discovery, but not later than three business days following discovery of the error. If the non-reporting counterparty does not know the identity of the reporting counterparty, the non-reporting counterparty shall notify the swap execution facility or designated contract market where the swap was executed of the error as soon as technologically practicable after discovery, but no later than three business days following the discovery. Such notice from the non-reporting counterparty to the swap execution facility, designated contract market, or reporting counterparty constitutes discovery under this section.

17 CFR 45.14(a)(3)

Correcting errors in swap data and verification of swap data accuracy (Correction of errors)

Exception. The requirements to correct errors set forth in paragraph (a) of this section only apply to errors in swap data relating to swaps for which the record retention period under § 45.2 has not expired as of the time the error is discovered. Errors in swap data relating to swaps for which the record retention periods under § 45.2 have expired at the time that the errors are discovered are not subject to the requirements to correct errors set forth in paragraph (a) of this section.

17 CFR 45.14(b)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

Verification that swap data is complete and accurate. Each reporting counterparty shall verify that there are no errors in the swap data for all open swaps that the reporting counterparty reported, or was required to report, to a swap data repository under the requirements of this part, in accordance with this paragraph (b).

17 CFR 45.14(b)(1)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

Method of verification. Each reporting counterparty shall utilize the mechanism for verification that each swap data repository to which the reporting counterparty reports swap data adopts under § 49.11 of this chapter. Each reporting counterparty shall utilize the relevant mechanism(s) to compare all swap data for each open swap for which it serves as the reporting counterparty maintained by the relevant swap data repository or repositories with all swap data contained in the reporting counterparty's internal books and records for each swap, to verify that there are no errors in the relevant swap data maintained by the swap data repository. Notwithstanding the foregoing, a reporting counterparty is not required to verify the accuracy and completeness of any swap data to which the reporting counterparty is not permitted access under the Act or Commission regulations, including, but not limited to, § 49.17 of this chapter.

17 CFR 45.14(b)(2)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

Verification policies and procedures. In performing verification as required by this paragraph, each reporting counterparty shall conform to each relevant swap data repository's verification policies and procedures created pursuant to § 49.11 of this chapter. If a reporting counterparty utilizes a third-party service provider to perform verification, the reporting counterparty shall conform to each relevant swap data repository's third-party service provider verification policies and procedures created pursuant to § 49.11 of this chapter and shall require the third-party service provider to conform to the same policies and procedures while performing verification on behalf of the reporting counterparty.

17 CFR 45.14(b)(3)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

Correcting errors. Any and all errors discovered during the verification process shall be corrected in accordance with paragraph (a)(1) of this section.

17 CFR 45.14(b)(4)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

Frequency. Each reporting counterparty shall perform verification at a minimum:

17 CFR 45.14(b)(4)(i)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

If the reporting counterparty is a swap dealer, major swap participant, or derivatives clearing organization, once every thirty calendar days; or

17 CFR 45.14(b)(4)(ii)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

If the reporting counterparty is not a swap dealer, major swap participant, or a derivatives clearing organization, once every calendar quarter, provided that there are at least two calendar months between verifications.

17 CFR 45.14(b)(5)

Correcting errors in swap data and verification of swap data accuracy (Verification that swap data is complete and accurate)

Verification log. Each reporting counterparty shall keep a log of each verification that it performs. For each verification, the log shall include all errors discovered during the verification, and the corrections performed under paragraph (a) of this section. This requirement is in addition to any other applicable reporting counterparty recordkeeping requirement.

17 CFR 45.14(c)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

Error defined

17 CFR 45.14(c)(1)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

Errors. For the purposes of this part, there is an error when swap data is not completely and accurately reported. This includes, but is not limited to, the following circumstances:

17 CFR 45.14(c)(1)(i)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

Any of the swap data for a swap reported to a swap data repository is incorrect or any of the swap data that is maintained by a swap data repository differs from any of the relevant swap data contained in the books and records of a party to the swap.

17 CFR 45.14(c)(1)(ii)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

Any of the swap data for a swap that is required to be reported to a swap data repository or to be maintained by a swap data repository is not reported to a swap data repository or is not maintained by the swap data repository as required by this part.

17 CFR 45.14(c)(1)(iii)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

None of the swap data for a swap that is required to be reported to a swap data repository or to be maintained by a swap data repository is reported to a swap data repository or is maintained by a swap data repository.

17 CFR 45.14(c)(1)(iv)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

Any of the swap data for a swap that is no longer an open swap is maintained by the swap data repository as if the swap is still an open swap.

17 CFR 45.14(c)(2)

Correcting errors in swap data and verification of swap data accuracy (Error defined)

Presumption. For the purposes of this section, there is a presumption that an error exists if the swap data that is maintained and disseminated by an SDR for a swap is not complete and accurate. This includes, but is not limited to, the swap data that the SDR makes available to the reporting counterparty for verification under § 49.11 of this chapter.

Shot Clock Start

DMO notification?

At what point to notify DMO?

Error Identification / Discovery

BAU Exception Management

NACK is investigated and successfully resubmitted within 7 business days of receiving the NACK

NACK receipt

No

N/A

NACK is investigated within 7 business days of receiving the NACK, confirmed as a legitimate issue, but cannot be successfully resubmitted within this window

NACK receipt

Yes

NACK receipt day + 7d

NACK is received but cannot be fully investigated within 7 days (could be a "false positive")

NACK receipt

Yes

NACK receipt day + 7d

NACK is received, is investigated within 7 business days and is confirmed as a "false positive" or otherwise not requiring resubmission

NACK receipt

No

N/A

An internal exception, generated by a pre-submission validation error on an issue that would have resulted in a NACK (e.g. missing or invalid data), is generated but cannot be fully investigated or resolved within 7 days

Internal exception receipt

Yes

Internal exception receipt day + 7d

An internal exception, generated by a pre-submission validation error on an issue that would have resulted in a NACK (e.g. missing or invalid data), is generated and is fully resolved and successfully resubmitted within 7 days

Internal exception receipt

No

N/A

An internal exception that would not have resulted in a NACK (e.g. accuracy discrepancy) is investigated, confirmed as a legitimate issue and cannot be successfully resubmitted within 7 days of the exception being confirmed as an issue

When exception is confirmed as issue

Yes

Issue confirmation date + 7d

An internal exception is generated but cannot be fully investigated within 7 days

When exception is confirmed as issue

Yes

Issue confirmation date + 7d

A previously notified issue is resolved in firm systems, but backreporting is pending on the impacted population

N/A

No

N/A

A previously notified issue is resolved and all impacted trades resubmitted

N/A

No

N/A

An issue that was previously notified to the DMO and subsequently resolved has reoccurred and cannot be resolved within 7 days

NACK/exception receipt

Yes

NACK/Exception start day +7d

BAU Reconciliation Process

Completeness/accuracy discrepancies are identified during routine reconciliation, but these are investigated and corrected within 7 business days of their identification

Completeness or accuracy break

No

N/A

Completeness/accuracy discrepancies can be investigated and confirmed as legitimate issues within 7 business days of their identification, but cannot be corrected within that timeframe

Completeness or accuracy break

Yes

Break + 7d

Completeness/accuracy discrepancies cannot be fully investigated nor corrected within 7 days of their identification (they could contain false positives)

When break is confirmed as an issue

Yes

Issue confirmation date + 7d

Part 45.14 Verification Process

The monthly verification process required under Part 45.14 cannot be completed within the month

Start of rec process

Yes

Start of rec process + 30d

Firms are able to investigate and correct all issues identified as part of Part 45.14 Verification within the 7 day deadline

Start of rec process

No

N/A

Firms are able to investigate the issues identified as part of the 45.14 vrification process within the 7 day deadline but not able to correct them and backreport on time

Start of rec process

Yes

Break + 7d

Firms are not able to investigate nor correct the breaks identified as part of Part 45.14 Verification process within the 7 day deadline (the breaks may contain "false positives")

Start of rec process

Yes

Break + 7d

Issues raised by non-Reporting Counterparties

Discrepancies are communicated to the RCP by a non-RCP. The RCP investigates and agrees with the error, and corrects it within 7 days of the notification

Notification date

No

N/A

Discrepancies are communicated to the RCP by a non-RCP. The RCP investigates and agrees with the error, but cannot correct it within 7 days of the notification

Notification date

Yes

Notification date +7d

Discrepancies are communicated to the RCP by a non-RCP. The RCP investigates within 7 days but does not agree with the error

Notification date

No

N/A

Discrepancies are communicated to the RCP by a non-RCP. The RCP is not able to prioritise investigation within 7 days and these "errors" may be legitimate interpretation differences or false positives

Notification date

Yes

Notification date +7d