Question ID: 2546
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Topic: Reporting Templates
Article: 35 of SII Directive
Template: S.06.02, S.08.01
Status: Final
Date of submission: 19 Dec 2022
Question
Please find below questions regarding Taxonomy 2.8.0 and QRTs S.06.02 and S.08.01:
S.06.02 :
A)
In field C0220 (Type of Issuer code), CIC 87 and 88, CIC 71, 75, and 9 are explicitly excluded from the reporting requirement. The field should remain empty for these CICs:
“Identification of the type of code used for the ‘Issuer Code’ item. One of the options in the following closed list shall be used:
1 — LEI
9 — None
This item is not applicable to CIC 87 and CIC 88.
This item is not applicable for CIC 71, CIC 75 and CIC category 9 — Property“
In the fields C0122 (Type of code of custodian) and C0260 (Type of issuer group code) this is not the case, here, if no LEI is specified, the value "9-None" must be reported for all CICs, also for the above explicitly mentioned CICs 87, 88, 71, 75 and 9.
We would like to kindly ask you to standardize the procedure for all similar fields (C0122 and C0260) or explain why the specifications are so different.
In addition, currently "9-None" does not have to be reported in field C0260 for all CIC 1 for which no Issuer Group and no Issuer Group Code have to be reported according to C0240 and C0250 (not applicable). Could this rule please be kept to avoid costly adjustments to the reporting.
At this point we would also like to refer to S.08.01. Here you have to proceed as follows according to your specifications in field C0340: When not applicable, this item shall not be reported. So the field remains empty. Thus, the field C0350 also remains empty and it is no longer necessary to report "9-None" as still according to 2.7.0. The same applies to C0280 (Type of counterparty code).
A uniform approach or logic, even across QRTs, would be desirable.
B)
According to our understanding, the field C0294 is only applicable for all CIC 13 and 14. Therefore, we have the question in which cases the value "9 - Not applicable" is applicable?
Can you please explain this or give us examples for which the value "9 - Not applicable" applies?
C)
In our opinion, there is a misalignment with new CIC Asset Categories 87,88 for C0320 (External Rating), C0330 (Nominated ECAI), C0340 (Credit quality Step) and C0350:
If we consider the ITS reporting instructions (AnnexII and AnnexIII), C0320 should be reported at least for CIC 1,2,5,6,87 and 88 instead C0330, C0340 and C0350 should be reported at least for CIC1,2,5,6,8 (other than 87,88). So, e.g., we report C0320 for CIC 87 and in the meantime we should respect the ITS Reporting, we should report also C0330, but as per ITS reporting below, it is not possible to report C0330 for CIC 87.
Could you please clarify the instruction how to correctly fulfill those data (C0320, C0330, C0340 and C0350 (Internal rating) for all CIC categories?
C0320:
Applicable at least to CIC categories 1 - Government bonds, 2 – Corporate bonds, 5 - Structured notes, 6 – Collateralised securities, CIC 87 and CIC 88, where available.
This is the issue rating of the asset at the reporting reference date as provided by the nominated credit assessment institution (ECAI).
C0330:
Applicable at least to CIC categories 1 - Government bonds, 2 – Corporate bonds, 5 - Structured notes, 6 – Collateralised securities and 8 - Mortgages and Loans, (other than CIC 87 and CIC 88), where available.
C0350:
Applicable at least to CIC categories 1- Government bonds, 2 – Corporate bonds, 5 - Structured notes, 6 – Collateralised securities and 8 - Mortgages and Loans, (other than CIC 87 and CIC 88), where available.
S.08.01:
A)
For field C0041 -Unique Transactions Identifier- you make the following specification:
"As many Trade IDs as needed to build the position being reported should be reported in this item. The trade IDs shall be reported separated by commas."
Can you please give us examples of derivative trades where such a case can occur. In which area of OTC trades do you see a need for action?
EIOPA answer
- S.06.02
A) The instructions are consistent with the corresponding "code". To ensure further consistency among different “codes" the exceptions for item C0220 will be removed in the future ITS amendments. However, please note that those exceptions are already in item C0210 and they are also referred in the beginning of the instructions of C0220.
Regarding your question that, currently "9-None" does not have to be reported in field C0260 for all CIC 1 for which no Issuer Group and no Issuer Group Code have to be reported according to C0240 and C0250 (not applicable) and whether this rule could be kept to avoid costly adjustments to the reporting please note that changes in the instructions are not possible at this time. It will be reviewed in the future ITS amendments.
Regarding your question on S.08.01 and the reporting of C0340, C0350 and C0280 – when not applicable 9-None should be reported.
- S.06.02: It applies to all other CIC.
- S.06.02:There is clearly a typo in the instructions of item, C0320 that will be corrected in the future ITS amendments.
2) S.08.01 - In this template, each position in a derivative, identified with item C0040 - Derivative ID Code, can be the aggregation of more than one transition in the trade repositories. In this case more than one UTI has to be reported. Some examples - https://www.esma.europa.eu/press-news/esma-news/esma-consults-emir-reporting-guidelines (page 134), https://www.esma.europa.eu/sites/default/files/library/esma74-362-2281_final_report_guidelines_emir_refit.pdf (page 250-255) and https://www.esma.europa.eu/sites/default/files/library/esma70-1861941480-52_qa_on_emir_implementation.pdf (pages 80,81, 130).