Validation rule v22095_h in Reporting Framework 3.5

The question concerns the EBA Reporting Framework 3.5, Validation Rules (19 December 2024), rule v22095_h.  This rule require that total amounts of Loans and Advances should be equal to the sum of sub-total amounts (Retail, Wholesale non-financial, Wholesale financial) in the context of Reporting on interest rate risk in the banking (specified in Section 12 – ‘Reporting on interest rate risk in the banking book’ of Annex I to Regulation (EU) 2024/3117, form J02.00 : {r0050} = +{r0080} + {r0100} + {r0110} Is the formula correct having in mind the possibility to have exposures from clients that do not satisfy definitions of sub-categories but have to be reported in "Loans and Advances"?

Validation rule v22095_h requires that total amounts of Loans and Advances should be equal to the sum of sub-total amounts (Retail, Wholesale non-financial, Wholesale financial) where definitions of sub-categories are following: * Retail: "Loans and advances to a natural person or an SME, where the exposure toward small and medium-sized enterprise (“SME”) is to qualify for the retail exposure class under the Standardized or Internal Ratings Based (“IRB”) approaches for credit risk as set out in Part one, Title II, Chapters 2 and 3 of Regulation (EU) No 575/2013 (CRR), or a company which is eligible for the treatment set out in Article 153(4) of Regulation (EU) No 575/2013 and where the aggregate deposits by that SME or company on a group basis do not exceed EUR 1 million. Both performing and non-performing retail loans and advances shall be reported in this row."  * Wholesale non-financial: "Loans and advances to general governments and non-financial corporations as referred to in Part 1, point 42(b) and (e), of Annex V to this Regulation. This row shall not include exposures included in row 0080." * Wholesale financial: "Loans and advances to other financial corporations as referred to in Part 1, point 42(d), of Annex V to this Regulation." Taking into account above mentioned definitions, it is possible to have Loans and Advances to customers not included in nor Retail nor Wholesale, i.e. "Non-profit institutions which serve households (‘NPISH’) and which are principally engaged in the production of non-market goods and services intended for particular groups of households" are by paragraph 42 of Part 1 of Annex V of the ITS on supervisory reporting included in "Households" and by CRR not included in Retail.