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Dear Sender,
Thank you for reaching out to ESMA. Please accept our apologies for the delayed response.
Regarding your question, as clarified in TR Question 3b of the Q&As on the implementation of EMIR, the mark-to-market (MtM) value should reflect the total value of the contract.
For Contracts for Difference (CFDs) that are not cleared by a Central Counterparty (CCP), the MtM value should be calculated as follows:
MtM = Quantity x End-of-Day Settlement Price
This calculated value should be reported under Field 2.21 - "Valuation amount" in accordance with EMIR reporting requirements. The conditions and dependencies for reporting in Field 2.21 are further outlined in the EMIR validation rules.
We hope this addresses your query. Please feel free to reach out if you require further clarification.
Kind regards,