We record purchases and sales of participations in „36.01“. Does line C0140 "Contract amount of the transaction / transaction price" contain every transaction (sale and purchase)? if so, what field is used to distinguish between buying and selling? The supervisory authority expects an initial value, a transaction (buy or sell) and a closing value. It is not clear to us what the initial value is and where it is entered. Furthermore, we would like to understand how to deal with price gains on repayments?
The ITS on reporting 2019 report that “Where similar transactions with a related entity may be excluded from IGT reporting when considered individually against the thresholds for significant and very significant, these transactions must nevertheless be individually reported where collectively they are at or above the corresponding threshold values for significant or very significant IGTs […] Each transaction shall be reported separately”. Furthermore, to distinguish between sale and purchase, the cells C0020 “Investor/lender name” and “C0030 Identification code for investor/lender” on one side and the cells “C0050 Issuer/borrower name” and “C0060 Identification code for issuer/borrower” shall be used. With regard to dealing with price gains on repayments, the ITS text, always stressing the instruction that each transaction shall be reported separately, also specifies “Where the transaction value is different for two transacting parties (e.g. a EUR 10 m transaction between A and B where A records EUR 10 m but B only receive EUR 9,5 m because of transactions costs, of say EUR 0,5 m has been expensed) the template shall record the maximum amount as the transaction amount, in this case EUR 10 m.