SOLVENCY TREATMENT: SECURITISATION POSITIONS SUBJECT TO OWN FUNDS REQUIREMENTS C14.00 Col 0060 – reporting requirement is inconsistent between the ITS and the latest version of the EBA Annotated Tables and EBA P3 mappings for templates EU-SEC1 and EU-SEC3

ANNEX II INSTRUCTIONS FOR REPORTING ON OWN FUNDS AND OWN FUNDS REQUIREMENTS C14.00 Col 0060 states the following: “ Originators, only , shall report one of the following:  - Not subject to own funds requirements. - Banking book; - Trading book; - Partially in banking and trading book.” Question 1 . The latest version of the EBA Annotated Tables for C14.00 col 0060 references the Role in the securitisation process = Originator, Sponsor.  This is inconsistent with the ITS, which refers to Originator securitisation exposures only.   Can we clarify whether EBA has expanded the scope of reporting for col 0060 to also include exposures where the Role in the securitisation process = Sponsor?  This is not a change that has been noted as part of CRR3 uplift requirements work. The associated EBA mapping logic for Template EU-SEC1, sections h to k, where Institution acts as sponsor for example (noted below) - the conditions are mutually exclusive, as within the current reporting process, C14.00, col 0060 is only populated in instances where the Role in the securitisation process = Originator. if(and({C 14.00, c0061} = N, {C 14.00, c0080}=A or D), {C 14.00, c0140}*{C 14.00, c0090}, if({C 14.00, c0061} ≠ N, {C 14.01, c0411})), where  {C 14.00, c0060} = Banking book,  {C 14.00, c0110} = Sponsor   Question 2. The reportable values noted above are consistent between the EBA annotated tables and the ITS, however the EBA mappings for Template EU-SEC1 and Template EU-SEC3 is limited to instances where C 14.00, c0060 = Banking book only.  Is it an intention of the EBA to only capture the banking book securitisations in these templates?  This is not in line with the scope of production P3 disclosures, which also considers values other than Banking Book.

As above.