Reporting Templates

We have a question regarding the CIC classification of investment funds that are established as AIFs. It is our understanding that shares in investment funds are generally to be reported under CIC 4, irrespective of their balance sheet classification (participation or not). However, we have experienced that such investments are also classified as CIC 3. Many of the investment funds in question are included in the ECB's IF list, which is published on its website („Lists of financial institutions (europa.eu)“). In the opinion of the ECB and the Deutsche Bundesbank, the definition of collective investment undertakings under ESA 2010 and the Technical Standards, Annex VI of Solvency II should be the same. A public clarification regarding the CIC classification of AIFs would be helpful. The same applies to international investment vehicles (e.g. SICAVs) which are set up in the form of an investment company.