Validation rules: v7374_m, v7375_m and v7377_m

Can EBA confirm that the validation rules v7374, v7375 and v7377 satisfy with paragraph 114 of Commission Implementing Regulation (EU) 2022/1994 of 21 November 2022 for investor positions?

In EBA Q&A 2022_6648, which comprises a similar question with regard to v7372 and v7373, the status of that question is under review by EBA. However, this EBA Q&A does not include v7374, v7375 and v7377. In the EBA validation rules (uploaded 12 December 2022), the following validation rules have been included with regard to template C14.01 v7374_m: [C 14.01 (All rows)] sum({{C 14.01, c0330, (sNNN)}}) <= {{C 14.00, c0250}} v7375_m: [C 14.01 (All rows)] sum({{C 14.01, c0340, (sNNN)}}) <= {{C 14.00, c0260  v7377_m: [C 14.01 (All rows)] sum({{C 14.01, c0360, (sNNN)}}) <= {{C 14.00, c0280}} However, paragraph 114 of Commission Implementing Regulation (EU) 2022/1994 of 21 November 2022 states as follows: “Because of Article 5 of Regulation (EU) 2017/2402, which establishes that institutions investing in securitisation positions shall acquire a great deal of information on them in order to comply with due diligence requirements, the reporting scope of the template shall be applied to investors to a limited extent. In particular, they shall report columns 0010-0040; 0070-0110; 0160; 0190; 0290-0300; 0310-0470.” Therefore in our view, the three above-entioned validation rules may not be required when following paragraph 114 of the ITS for investor positions as the columns 250, 260 and 280 are not mentioned in this paragraph 114.