Reporting of credit risk mitigation on the CR IRB template (C 08.01)

The COREP CR IRB guidelines seem to be conflicting with the validation rules in respect to reporting the substitution effect of Credit Risk Mitigation (CRM), columns 40-80 of the CR IRB template. The instruction for column 040 (Guarantees) is ambiguous, on the other hand it states: "If the CRM effect of the guarantee is calculated by recognition of the substitution effect, the Adjusted Value (Ga) as defined in Article 236 of CRR shall be provided." but also: "When Own estimates of LGD are used: Article 183 of CRR, except paragraph 3. The nominal amount of the guarantees shall be reported." For the substitution approach, the adjusted value of guarantee has to be reported in the column 070 (outflows). The COREP CR IRB template states that the column 070=040+050+060. This formula woud result in the nominal (pre-currency/maturity mismath adjustment) value being transferred from the original obligor's exposure class to the protection provider's exposure class, instead of the adjusted amount. Please clarify which amount is to be reported in the columns 040-050, nominal or adjusted credit protection amounts? In case the answer is different for banks using own LGD estimates and those not, please specify why should this be the case.

See above.