Reporting of unused prior permission amounts with no specification of subordination

A  word-by-word interpretation of the Commission Implementing Regulation would indicate the following in case the unused prior permission amount exceeds the eligible liabilities subordinated to excluded liabilities (M02.00-r0100 to M02.00-r0130):  Reporting the full amount of unused prior permission amounts in r0132 and r0135 and a zero in r0090, leading to a breach of validation rules. In this case, banks would need to deduct a larger value than the sum of subtotals which appears contradictory  or ​ Reporting the full amount of unused prior permission amounts in r0132 and r0135 and the gross amounts in r0090 and r0140, but the net amounts in r0060 and r0070, also leading to a breach of validation rules.  Since both options would lead to inconsistencies and the breach of several validation rules, we would propose the following solution:  In case, the unused prior permission amount exceeds the amount of eligible liabilities subordinated to excluded liabilities (M02.00-r0100 to M02.00-r0130), the deductions in r0132 and r0135 shall only be considered up to the extent of available subordinated eligible liabilities except for T2 in phase-out. The residual amount of unused prior permission amounts shall be reported in r0162 and r0165 in the field for eligible liabilities not subordinated to excluded liabilities. This solution would also be in line with the published validation rules and not lead to a breach.  For the purposes of the reporting of MREL, T2 in phase-out should already by reported net of prior permission amounts for own funds instruments where applicable.