C 34.06 – Top twenty counterparties

In the COREP Own Funds reporting template C 34.06 the top 20 counterparties ranked by CCR exposure shall be shown. If a counterparty acts both as QCCP and as Non-QCCP/bilateral counterparty, should the counterparty be listed twice in the template or only once with the higher exposure?

Annex 2 (chapter 3.9.7) does not mention whether double reporting of a counterparty - once as QCCP and once as Non-QCCP - is allowed. There are three options: a) The counterparty is to be named twice (i.e. once with the QCCP exposure and once with the Non-QCCP exposure). But this presentation would not be compliant with validation rule v10473_u as the primary key consisting of the CODE (column 0020) and TYPE OF CODE (column 0030) must be unique. b) The counterparty is to be named only once with aggregated exposure (i.e. aggregating the QCCP-exposure and the Non-QCCP exposure). This would lead to a wrong counterparty type in column 0050 where only one type of counterparty can be selected. Which should it be? QCCP or Non-QCCP/bilateral counterparty? Furthermore, this would lead to an inconsistent risk weight as the risk weight applied to QCCPs differs from the risk weight applied to Non-QCCPs. c) The counterparty is to be named only once with only one exposure (i.e. only the highest CRR exposure). Doing so when there are less than 20 counterparties would mean that the risk weighted assets reported in C 34.06 would be less than the risk weighted assets reported in template C 34.02.