EIOPA created the CIC code as a code to be reported by insurance and reinsurance undertakings to supervisory authorities. Insurance and reinsurance undertakings are responsible for the CIC attributed to each asset as according to the Directive insurance and reinsurance undertakings shall only invest in assets and instruments whose risks the undertaking concerned can properly identify, measure, monitor, manage, control and report, and appropriately take into account in the assessment of its overall solvency needs. EIOPA believes that by identifying the CIC code undertakings are being assessed by the knowledge of its own portfolio. 
 
How each insurance and reinsurance undertaking will attribute the CIC code is not relevant to EIOPA as long as they are able to answer any queries from their own supervisory authorities. Summing up the creation of CIC codes is not restricted to anyone. 
 
As to how to identify primary exchange if a bond trades on multiple exchanges we don’t really understand the question in relation to the CIC code. To identify the country if the asset is listed in more than one country, the country should be one where the most liquid regulated market is located. However, from a service provider's perspective, the country ISO to use as default could be the primary exchange.