COREP C14.00, columns 0140-0225, validation rules v11650_m, v11651_m and v7347_m

Pursuant to para (a) of the definition of originator, the submitter qualifies as the sole originator as an entity which itself or through related entities, directly or indirectly, was involved in the original agreements which created the obligations of the debtors giving rise to the exposures being securitized.  The securitized exposures/obligations were not on the submitter’s balance sheet.  However, given the definition of originator (in particular para (a)) we understand that the presence of the securitized exposures/obligations on an entity’s balance sheet, is not a condition for such entity to qualify as an originator (including as the sole originator). We further understand that in the templates C14.00, the section securitized exposures, columns 0140-0225: apply to an originator of securitization positions which were securitized from such originator’s own balance sheet (‘own portfolio’); do not apply to an originator where the securitization positions were not on such originator’s own balance sheet. If our understanding is correct, please confirm that the submitter, as a sole originator which did not have the securitized exposures/obligations on its balance sheet, should not be required to populate section Securitised Exposures, columns 0140-0225?

This question is interconnected with validation rules v11650_m, v11651_m and v7347_m. It seems the rules assume that an originator would always securitize its own portfolio (when underlying loans are provided from the originator’s own balance sheet), which might not necessarily always be the case in practice given para (a) of the definition of originator.