Question ID: 2844
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Article: N/A
Template: S.08.01
Status: Final
Date of submission: 26 Oct 2023
Question
In the EU2023/894 S.08.01 guidance, it says "This template comprises two tables: Information on positions held and Information on derivatives. On the table Information on positions held, each derivative shall be reported separately in as many rows as needed in order to properly fill in all non-monetary variables, requested in that table. If for the same derivative two values can be attributed to one variable, then this derivative needs to be reported in more than one line. In particular, for derivatives that have more than a pair of currencies, it shall be split into the pair components and reported in different rows." In the Q&A1457, It says "In S.08.01 each derivative has to be reported in one row. If there are frequent trades on the same derivative, resulting in multiple open positions, the derivative can be reported on an aggregated or net basis, as long as all the relevant characteristics are common and following the specific instruction for each relevant item. Please consult also Q&A 752." and then "In S.08.01 the duration should be reported net and consequently the derivatives should be reported in one single row each. The general principle of splitting between lines makes sense when what is different is the derivatives' characteristics. Duration of a derivative, although calculated based on more than one set of cash flows, is a unique measure. " We now encountered an scenario, where we have 2 asset, IRS and XCCYIRS which both needs duration reporting. Based on the guidance in Q&A, can you please confirm if below treatments are correct:
1. For IRS, duration is reported net and both fix and float legs are combined as 1 line.
2. For XCCYIRS (if we have 1 pair of currency), duration is reported net and both fix and float legs are combined as 1 line.
3. For XCCYIRS (If we have 2 currency pair as structure), duration is then reported in separate lines for each of the legs, i.e. 4 rows?
EIOPA answer
EIOPA confirms the treatment for 1 and 2. For three, if there are 2 currency pairs, it can be reported in 2 lines.