Member firms should note that on May 28th ESMA published an update of their Q&A for this regulation which included some clarification on the use of “easy-to-borrow purchase” lists as a confirmation of a security being “easy to borrow”.
The document can be found here: https://www.esma.europa.eu/sites/default/files/library/esma70-145-408_qa_on_ssr.pdf
Whilst ISLA have reviewed the new wording, it does not intend to respond or seek further clarification unless member firms request such action
However, member firms may need to review locate processes to ensure on-going compliance. Find a brief summary of the ISLA findings here.