Confirmation is sought on how to report a cascade of transaction.

For the purpose of intra-group transaction reporting, the Annex II of Commission Implementing Regulation (EU) 2022/2454 (section 2.1, 3.1, 4.1, 5.1 and 6.1) clarifies that “where there is a chain of related intra-group transactions (e.g. A invests in B and B invests in C), such transaction shall be reported as an indirect transaction. Therefore, A to C transactions shall be reported and the intermediary steps shall be mentioned in the comments. In the case of a cascade of transactions (e.g. from A to B to C to D sequentially, where both B and C are in the conglomerate but are unregulated entities), those transactions shall also be reported.”

In accordance with the above general guideline and the instruction provided for columns 0020, 0040, 0050, 0070 and 0080, the following approach shall apply :

-          In case where intermediary entities are part of the financial conglomerates, including non regulated entities, each step shall be reported in a separate line and a specific ID shall be provided column 0080 in order to identify the transactions comprised in a given chain;

-          In case where intermediary entities are third parties, only the transactions between entities that are part of the financial conglomerates shall be reported in a separated lines, intermediary steps involving third parties have to be mentioned in comment.

Below a simplified illustration of the reporting expectations where A (a bank of the financial conglomerate) lend to B (third party) which in turn lend to C (an investment firm of the financial conglomerate) which in turn lend to D (an insurance of the financial conglomerate):