Column 100 of the C 25.00 - CVA RISK template required the number of counterparties to be reported. The situation arises whereby some OTC derivatives counterparties have Zero EAD and therefore have no CVA charge. If these counterparties are part of a group, some of the members of which have Non-Zero CVA charges, then it is not clear whether the counterparty with a Zero CVA charge should be included in the count that is required to be reported in column 100 of template C25.00 - CVA Risk. The following guidance in the Annex 2 of Final draft ITS on Supervisory Reporting (EBA-ITS-2017-01), regarding column 100 of the C25.00 is not clear on whether counterparties with Zero EAD and CVA are considered “counterparties included in calculation of own funds for CVA risk”, since their CVA risk is Zero. Annex 2 guidance on C25.00; column 100: “Article 382 of CRR. Number of counterparties included in calculation of own funds for CVA risk. Counterparties are a subset of obligors. They only exist in case of derivatives transactions or SFTs where they are simply the other contracting party.” It could be argued that most likely use of the counterparty count alongside the total corresponding EAD and/or CVA exposure is to get the average EAD and/or CVA charge per counterparty. For example, if the CVA Charge is 100 and there are 4 counterparties in the group, then the average CVA charge per counterparty would be 25. But if one of the counterparties in the group actually had a Zero CVA charge included in this total 100, then the average CVA charge of 25 would be skewed and biased. Therefore, it is more in line with the spirit of the rules that where the EAD is Zero, that that counterparty is excluded from the count. We have seen this in other areas of the rules, such as when calculating the Operational risk charge using the Basic Indicator Approach, where for any given year, the relevant indicator is negative or equal to zero, institutions are required not take into account this figure in the calculation of the yearly average. They shall then calculate the average over three years as the sum of positive figures divided by the number of positive figures. As there is no clear guidance from the EBA on this, aside from the above considerations, it is open to debate as to whether counterparties with Zero CVA should be counted towards the number of counterparties that contributed to the EAD and CVA charge, that is required to be reported in template C25.00 column 100.