Outflow of liquidity facilities provided to an SSPE

Based on article 31 (6) of the Delegated Regulation 2015/61 including amendments should the bank apply 10% outflow to an undrawn committed liquidity facility that has been provided to an SSPE for the purpose of enabling that SSPE to purchase mortgages from a financial customer?

The text of article 31 paragraph 6 is: "6.   The undrawn committed amount of a liquidity facility that has been provided to an SSPE for the purpose of enabling that SSPE to purchase assets, other than securities, from clients that are not financial customers shall be multiplied by 10 % to the extent that it exceeds the amount of assets currently purchased from clients and where the maximum amount that can be drawn down is contractually limited to the amount of assets currently purchased." The place of the comma after "other than securities, " is essential for understanding this article. The place of the comma currently suggest that the outflow percentage of 10% has to be applied to an undrawn committed liquidity facility provided to an SSPE for the purpose of enabling that SSPE to purchase assets from non-financial customers, as long as these assets are not securities. So warehousing of mortgages from a mortgage provider would not fall within the definition because a mortgage provider is a financial customer. However in the instructions to template C73.00 the comma is put after "that are not financial customers". This is also the place of the comma in the Dutch translation of the Delegated Regulation. That would mean that the 10% has to be applied to undrawn committed liquidity facilities provided to an SSPE for the purpose of enabling that SSPE to purchase assets. This purchase could then also be from financial customers as long as these assets are not securities from non-financial customers. Example An SSPE is purchasing mortgages from a mortgage provider (financial customer). The total limit of the liquidity facility is 500. The mortgages that are already purchased and externally funded by the SSPE are 300. The undrawn committed amount of the liquidity facility is 500 and can only be used to purchase assets (mortgages) from the originator. Should we use 10% to calculate the outflow on the undrawn committed amount of 500?