Failed rule EGDQ_0875 – proposed check on 12/2023 FP

How to cope with the issue described below for the future EBA Funding Plan deliveries avoiding any “failed” rule?

The validation rule “EGDQ_0875” has been implemented as a proposed check for EBA Funding Plan 2023 for the first time and referring to the EBA Funding Plan template “P_01_01_Asset balance”. The description of this rule is as follows:  “If geographical breakdown is reported in FINREP, the domestic loans and advances to households and corporations, other loans and advances and reverse repurchase loans ({r020+r040+r110+r181+r191+r195+r197,c010}) are expected to be more than the domestic loans and advances in FINREP ({F20.01,r0090+r0095+r0099+r0130+r0144+r0174+r0178+r0183+r0233+r0237,c0010})” In our point of view this validation rule leads to an error since the volumes of “counterparty split (e.g. row codes 030, 100, 180, …..)”, which is the supercategory of geographical breakdown, come from another FinRep table  F05.01. The problem we see is, that the “Loan and advances” definition of F05.01 (counterparty split) is different to F20.01 (geographical breakdown). The table F05.01 includes the position “other demand deposits” and excludes the position “trading loans and advances” while in F20.01 it is vice versa. Due to different “loans and advances” definition the volume can’t match and thus rule will lead to an error.