We have a question regarding the CIC for the OTC IRS SWAP through CCP (Central Clearing house). We representing this as XTD1. Would you also expect the first two letters of the CIC for the OTC IRS Swap through CCP? If not, what do you expect to see as the first two letters for the IRS Swap by CCP.

In the EIOPA logfiles S.08.01 and S.08.02 the field Counterparty Group is only applicable for Over-the-Counter (OTC) derivatives, not through exchange or CCP, isn't is. I left this field empty, as this is an OTC IRS Swap through CCP? Do you agree with this?