FINREP table 1.1 vs 20.4 – “cash and cash balances at central bank” and “other demand deposits”

In FINREP v2.8, under validation rules v5273_m; v5286_m and v5312_m for “Loans and advances” the “Gross carrying amount’ and ‘Accumulated impairment’ of template F 18.00 are consistent with the “Gross carrying amount’ and ‘Accumulated impairment’  of  template F 20.4 According to Part 2, paragraph 217 of Annex V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), template F 18.00 covers also cash balances at central banks and other demand deposits. In particular, for the purpose of template 18 “‘exposures shall include all debt instruments (debt securities and loans and advances which shall include also cash balances at central banks and other demand deposits) and off-balance sheet exposures, except those held for trading exposures." As a result, table F 20.4 row 140 column 010 - Loans and advances [Gross Carrying amount] contains also the gross carrying amount referred to cash balances at central banks and other demand deposits. In FINREP v2.9, an ad-hoc row for cash balances has been added in F 18.00, but not in F 20.4, this does not change the fact that table F 20.4 row 140 column 010 - Loans and advances [Gross Carrying amount] contains also the gross carrying amount referred to cash balances at central banks and other demand deposits.