In your answer dated 6 june 2014, you stated that "Country of custody is mandatory to CIC categories 1 to 6. EIOPA will clarify this when drafting the Reporting Technical Standard."

Within the last 2.06.02 log file (annex II of the ITS under consultation from december 2014 to march 2015) it is said that "country of custody" has to be considered applicable to all CIC categories except for 8 and 95. Should this clarification be considered applicable to the preparatory phase too?

EIOPA answer

The final instructions read: “This item is not applicable for CIC category 8 – Mortgages and Loans (for mortgages and loans to natural persons, as those assets are not required to be individualised), CIC 71, CIC 75 and for CIC 95 – Plant and equipment (for own use) for the same reason. Regarding CIC Category 9, excluding CIC 95 – Plant and equipment (for own use), the issuer country is assessed by the address of the property.”

This should be considered in the preparatory phase on a best effort-basis.