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.