First issue: sign convention According to Annex II to Regulation (EU) No 680/2014 (ITS on Reporting), column 225 of template C14.00 is a memorandum item that should contain the credit risk adjustments (as defined in article 110 CRR) that have been booked during the current period. In most occasions it should contain therefore an “expense”, but since during the period reversions of past expenses may take place, the column could contain an “income”. That is, whatever the convention followed, the sign could vary according to the nature of the credit risk adjustment. Validation rule v3756_s indicates that this column should always (or in most cases, since the severity is “warning” for now) be positive; we understand this might be following the convention for memo items in C09.01.a and C09.02. However, while in C09.01.a and C09.02 the amount should always correspond to a net expense (and therefore there is no risk of sign misinterpretation), this is not always the case in column 225 of C14.00. Therefore, that convention should not apply. Otherwise, it follows that a positive value is expected in case of expenses and a negative value in case of net reversions, which is not intuitive and it may confuse both reporting institutions and information analysts. It would also give rise to data quality issues, since it would require additional checks to distinguish which signs would be following the counterintuitive convention and which signs would be wrongly reported. In conclusion, we suggest that validation rule is amended to take column 225 out of its scope. In addition, a new rule could be created to include the column, with formula {C 14.00} <= 0 to indicate the most frequent expectation and severity kept as “warning”. We also see no reason why the severity of rule v2054_s should not be upgraded to “error”. Second issue: definition of “current period” There is currently no definition of what “current period” means for this column, which may lead to interpretations. The instructions should be amended to clarify whether it follows the criteria of “period” in C09.01.b and C09.02 (3-month period since the last reporting reference date) or accumulated in the year as in C17.01 (i.e. from 1 January to 30 June of the calendar year for the June report, and from 1 January to 31 December of the calendar year in the December report). Finally, we understand it should be considered whether the DPM definition for this column should change from “stock” to “flow”.