Credit for consumption

How should "Credit for consumption" be interpreted for reporting in FINREP templates 5.1, 7.1, 18, 19 and 20.4? There appears to be two plausible and defendable means of determining the intended scope.

The ITS reference in Annex V.Part2.88(a) states that ‘Credit for consumption’ shall include loans granted mainly for the personal consumption of goods and services, and references the ECB BSI Regulation. Within the BSI Regulation, the table on Instrument categories lists Loans as category 2, which is further split out into a number of items such as 1.(a) loans granted to households and non-profit institutions serving households; 1.(b) credit card debt; and 1.(c) revolving loans and overdrafts etc. Credit for consumption is defined in 1.(a)(i) of the Loans category, but what is not clear is whether Credit for consumption is also applicable to other items within the broader category of Loans, and if so, to what extent. Arguably, whilst not directly acknowledged as part of a further breakdown, one could reasonably deduct that Credit card debt, and Revolving loans and facilities are also in part made up of Credit for consumption, as per the definition. As such, is it the intention of the regulator to limit Credit for consumption to: i) Loans granted to households and non-profit institutions serving households only (Category 2, item 1 (a)) (narrower scope); ii) Loans granted to households and non-profit institutions serving households, Credit card debt, and Revolving loans and overdrafts (Category 2, items 1 (a) - (c)) (broader scope); or iii) All items in Category 2 (a) – (k) (broadest scope)? The current validation rules support all three interpretations. For example, in template F:05, the total of Loans and advances should be >= the sum of the two of which purposes.