Re: Issuer Name, Issuer Sector, Issuer Group and Issuer Country fields

CIC 7: Could EIOPA clarify if Issuer information should be populated for CIC 7 (cash) securities and if so how it should be populated. For Cash Deposits for example (CIC 71) would the Issuer be the appropriate Central Bank?

CIC 8: The guidance provided in the log files only exclude Mortgages and Loans to individuals (which do not have a specific CIC Code) and not the whole of CIC8.

Could EIOPA clarify that Issuer Information is therefore required for other CIC8 assets.

If information is required, could EIOPA also clarify what should be populated as the Issuer for Mortgages and Loans? Should it be the lender (which in many cases would be the reporting entity itself since these are assets on the Balance sheet) or the borrower/counterparty?

CIC 9: Could EIOPA clarify that Issuer Information is not required for any CIC 9 assets (and not just CIC 95 as per the regulations) as no Issuer exists for Property ?