FINREP_3.2.1; F 40.01; Validation Rule EBA_v10676

Template F40.01 contains (among others) column 0110 (Accumulated equity interest [%]) and 0120 (Voting Rights [%]) which are left empty for some rows and therefore trigger a validation error as defined by the EBA. In our reporting empty does NOT mean 0 and therefore using empty fields instead of zero is a more appropriate approach to complete form 40,01. Is this approach correct? What should be reported?

Such validation rule cannot be complied with, since we are obliged to report all subsidiaries, consolidated structured entities and entities accounted for at equity (as presented in DB Groups' List of Shareholdings following the Groups’ GAAP, i.e., IFRS) into FinRep Form 40,01. Some entities are shown with 0% where we either own a de-minimis stake of below 0.05% (displaying then in the tables as 0.0% being rounded down) or where there is no capital in existence at all but voting rights (then as well displaying this as 0.0%). In particular with regard to consolidated structured entities we have as well such cases where DB does not inject any equity at all (hence are not owning any legal stake) or have respective voting rights attached. In such cases the fields C110 / C120 are empty. Hence, for the majority of such cases we consolidate such entities under IFRS since DB has power, variable returns and the ability to influence variable returns.