Template C 68.00 seeks to collect information about the reporting institutions' concentration of funding by product type, broken down into the listed funding types. After giving a broken-down list of funding types, the ITS in point 1.3.2 establishes that ‘for the purpose of completing this template, institutions shall report the total amount of funding received from each product category, which exceeds a threshold of 1 % of total liabilities’.Later, in point 1.3.4 the ITS states that ‘for the purpose of determining those product types from which funding obtained is greater than 1% of total liabilities threshold, the currency is irrelevant’.The doubt arises because in point 1.3.2, the ITS talks about ‘product category whereas in point 1.3.4 and also in the rest of the template, the ITS uses ‘product types’. Although the spirit of the regulation may suggest that both refer to the same concept, it is not clear that ‘product category’ and ‘product type’ can be considered interchangeable and have the same meaning.In either case, some clarification is needed.1) Therefore, what does the ITS mean by ‘product category’? Would it be the same meaning as ‘product type’? In either case, a complete description of what is understood as ‘product type’ or ‘product category’ would be helpful.2) In this line, and assuming that product type and product category are the same, then, each row of template C 68.00 would be considered a different product type / product category?If so, are they exclusionary?If they are, what are the concepts that have priority?For instance, if we have an unsecured wholesale funding that is both i) of which financial customers and ii) of which from intra-group entities, under which type should it be reported?
- Legal act: Regulation (EU) No 575/2013 (CRR)
- COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
