if in a SME action for the general interest of the project the SME pays the RTD performer before schedule, and this results in penalties to the SME – can this bank penalties be declared as eligible costs?

I am in the process of drafting a Consortium Agreement for a ITN. Does anyone have specific adaptions that they would suggest to the DESCA model in order for it to fit better to ITNs?

There are for example specific challenges regarding the training costs, which should be divided between the parties. Further there are associated partners involved, which is an exception in FP7 projects.

I would welcome any input on these issues.