The current regulation is requesting KID document to be written in the official language of the country where investment product is being offered. Is there a way for customer to overcome this rule by proving in any way that he is able to understand KID language?

Should a financial conglomerate decide the reporting unit (R03)?

How to report public sector and financial sector concentration in template (template FC07-00)?

Considering the definition of intragroup transactions provided in article 2(18) of Directive 2002/87/EC, we would like to confirm whether transactions between non-regulated entities of the financial conglomerate shall be reported.

Annex II to the Final Draft Report briefly mentions the “waterfall” example: A invests in B (e.g. purchases shares), B in C and C in D, where B and C are unregulated units of the conglomerate. This transaction shall be taken into account as specified. => In my view, A would not have to report a transaction (since investment does not meet a liability, see above), B and C would not have to act as they are not supervised, only D would have to report, as a supervised entity and through the sale of shares, funds flow, namely transaction A => D. Is this view correct?

In the draft ITS on the reporting of intra-group transactions and risk concentration, in the section “Current requirements as regards the reporting of information on risk concentration” (starting on page 9) it is proposed to report also the indirect exposures of a credit institution or investment firm belonging to a financial conglomerate (page 11). Here, indirect exposures are defined by the application of the substitution approach in Article 403 of Regulation (EU) No 575/2013, i.e. under the regulation for credit institutions and investment firms. Question: Do exposures of insurance companies belonging to a financial conglomerate therefore not fall under this new reporting requirement?

For the purpose of completing the reporting of significant risk concentration under Commission Implementing Regulation (EU) 2022/2454:

Question A: for the completion of templates FC.07 and FC.08 related to concentration, how should non-significant concentration be considered?

For the completion of template “FC.06 Risk Concentration - Exposure by counterparties”, could you clarify which methodology shall be used for determining the value of exposure to be reported, in particular for repo / reverse repo and derivatives?

Could you clarify in which case it shall be considered that a transaction is shifting risk exposures between entities outside the financial conglomerate (but where ultimately the risk exposure is brought back or stays within the financial conglomerate)? Shall transactions with non-consolidated SPV be considered as such indirect intragroup transactions to be reported or be considered as shifting risk outside the financial conglomerate and therefore are not required to be reported?