Question ID: 3353
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.08.01
Status: Rejected
Date of submission: 26 May 2025
Question
We have a question regarding S.08.01: C0140 - Buyer/Seller. The current requirement for this field asks for one of the following options to be reported, with the exception of interest rate swaps:
1 - Buyer
2 - Seller
For interest rate swaps one of the options in the following closed list shall be use:
3 - FX-FL: Deliver fixed-for-floating
4 - FX-FX: Deliver fixed-for-fixed
5 - FL-FX: Deliver floating-for-fixed
6 - FL-FL: Deliver floating-for-floating
We would like to seek clarification on why options three to six are only applicable to interest rate swaps. When entering a swap agreement, one is always both a buyer and seller of an agreed underlying.
Based on which criteria would EIOPA report a Swap as 1 - Buyer or 2 - Seller?
EIOPA answer
The question has been rejected as the issue it deals with is sufficiently clear from the instructions of S.08.01 in the ITS on Reporting.
Options 3 through 6 (FX-FL, FX-FX, FL-FX, and FL-FL) are specifically designed to capture the exchange of cash flow patterns unique to Interest Rate Swaps (IRS). These options allow the supervisor to identify which leg is fixed and which is floating (or if both are the same) within a single reporting line.
Regarding the definition of the buyer and seller positions, please note that the position is defined relatively to the security or notional amount and the swap flows. Consequently, Instructions for Cell C0140 in S.08.01 of the ITS on Reporting already provide a clear definition of “buyer” and “seller” of a swap.