Template F 22.02: Assets involved in the services provided

Instructions in paragraph 285, Part 2 of Annex V to Regulation (EU) 2021/451 (ITS) do not explicitly specify whether third party loan portfolios managed by the institution as loan servicer provider should be reported in F 22.02 as a requirement. Indeed, it is reported in F 22.01 as Loan servicing activities but loan servicing and asset management in F 22.02 are two different concepts which cannot be assimilated (please see here below). Other rows in F 22.02 (under Asset management and in general in this template) do not fit to report loan servicing. Consequently, the appropriate solution would be not to report the loan portfolio as asset involved in the servicing services provided in F 22.02.   Paragraph 284, letter (o), Part 2 of Annex V to the ITS: ' (o) Fees from ‘Loan servicing activities’ shall include, on the income side, the fee and commission income generated by the institution providing loan servicing services and on the expense side, the fee and commission expense charged to the institution by loan service providers '.  Paragraph 285, letter (a), Part 2 of Annex V to the ITS: ' (a) ‘Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management. ‘Asset management’ shall be reported by type of customer: collective investment undertakings, pension funds, customer portfolios managed on a discretionary basis, and other investment vehicles'.