[ESMA 33-128-563 Securitisation Q&A, Q&A 5.2.19]

The period of time during which these fields are expected to look back to is the entire life of the underlying exposure, including the time before the date at which it has been securitised/transferred to the SSPE. For example, cumulative prepayments should reflect all prepayments made on the underlying exposure both before and after the date of securitisation/transfer to the SSPE. As another example, if the date at which an underlying exposure was last in arrears was a date before it was securitised/transferred to the SSPE, and the underlying exposure has not been in arrears since that date (even after being securitised/transferred to the SSPE), then that initial date of arrears should be entered in the Date Last in Arrears field. Similarly, if there was a principal grace period end date that took place in the past (i.e. before the data cut-off date, or even before the date of submission), this should also be provided.

In the event of multiple dates where an event has taken place, specific provisions are set out in the Content to Report for most fields (e.g. CREL57, CREL82, and the Date of Restructuring fields). Where this is not the case,  the most recent date must be provided. See also Q&As 1283, 1286, 1288, 1290, 1291, 1295.