For row 010, column 010 of F18.00a, validation rules v5434_m states: {F 18.00.a, r010, c010} = sum({F 04.09, r010, (c010, c020)}) + sum({F 04.10, r060, (c010, c020)}) - sum({F 04.10, r060, (c015, c025)}). Accordingly, in range v5435_m to 5447_m the same comparison is made between F18.00a rows 020-180, column 010 and the matching rows in F04.09 and F04.10. Do these rules use the correct column references in F04.10 (gross carrying amount)?

We think the rules should compare the gross carrying amount of DEBT INSTRUMENTS AT COST OR AT AMORTISED COST (rows 010-180 c010 in F18) with the gross carrying amount of Unimpaired and Impaired assets of Non-trading non-derivative financial assets measured at a cost-based method (Columns 010 and 020 of F04.09) and the gross carrying amount of Unimpaired and Impaired assets of Other non-trading non-derivative financial assets (Columns 015 and 020 of F04.10) but excluding the gross carrying amount of assets measured at strict LOCOM (Columns 016 and 025 of F04.10) (since these assets are to be reported in rows 211-231 of F18). Is it possible that the validation rules use the wrong column references in F04.10, since C010 of F04.10 refers to the carrying amount instead of the gross carrying amount.