Question ID
2021_6036
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex V, para. 285
Type of submitter
Competent authority
Subject matter
Template F 22.02: Assets involved in the services provided
Question

Third party investment products distributed by an institution should be reported under “Assets Management” (F 22.02, r0010, c0010), “Custody Assets” (F 22.02, r0060, c0010) or “Customer resources distributed but not managed” (F 22.02, r0130, c0010)?

Background on the question

An institution has a strategic partnership with an external provider of equity and bond funds, and sells the products of this external provider (e.g. CIUs, funds or life insurance policies which are promoted by specialised asset management companies or insurance companies) within its network. The institution categorizes these assets as under management in its financial statement because, when distributing these products, consultancy and advisory are provided to the customers, and therefore this activity is distinguished from mere custody. For the purpose of reporting in FINREP template F 22.02 though, it is not clear how to interpret the reporting instruction to determine the allocation of such assets across the different rows.

Submission date
Final publishing date
Final answer

As they are not managed by the reporting institution, the products cannot be categorized in “Assets management” (row 0010 of F 22.02). As they are distributed by the reporting institution, they cannot either be categorized merely as “Custody”,
The products should be reported as “Customer resources distributed but not managed” (F 22.02, r0130, c0010).

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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