Alignment of total funding between FINREP F01.02 and COREP C67.00

What is the correct approach regarding the alignment between the FINREP F01.02 and COREP C67.00 templates as required by the AMM ITS since (1) the scope of consolidation might be different between the two reports and (2) different netting rules can apply between the two reports?

Following paragraph 1.2 (5) of Annex XIX of Commission Implementing Regulation 2021/451 (amended by Commission Implementing Regulation 2022/185 and Commission Implementing Regulation 2022/1994)  it is expected that the sum of section 1 of C67.00 (Top ten counterparties) and section 2 of C67.00 (All other funding) shall equal an institution’s total funding as per its balance sheet reported under the financial reporting framework (FINREP). However, this seems inconsistent with the EBA’s response to EBA Q&A 2015_2365 where the response includes “ Note that differences in the scope of consolidation as per Article 18 of Regulation (EU) No 575/2013 may hamper the possibility to ensure reconciliation of data sources ”. Moreover, the FINREP report requires to present the total funding on a net basis whereas applying the general principles for liquidity reporting towards C67.00 template leads to presenting certain positions of the total funding on a gross basis (mostly repurchase and reverse repurchase agreements). Therefore, the reconciliation of the figures between the two reports is not possible and thus is not in line with the AMM ITS. Therefore, we would appreciate receiving guidance whether C67.00 and F01.02 figures must align and which netting principles need to be applied on the C67.00.