Reporting templates on risk concentrations and intra-group transactions for conglomerates (FICOD), Reporting Templates

We have a question regarding S.37.01 Cell C0320 – Exemptions (included in the Implementing Regulation 2023/894), where we seek clarification of what information is asked for specifically. The cell C0320 makes reference to Article 187 in the delegated regulation, and in its reporting events, EIOPA has also referred to the banking regulation (Article 400 in the Regulation (EU) No 575/2013); We understand this is because both articles/legislations are referred to in the FICOD reporting requirements (Implementing Regulation 2022/2454, template FC.06, cell FC0270). While these two regulations appear to deal with the regulatory capital treatment of large exposures, we are not entirely sure if their actual treatment is the same; As we read the Article 187 (Specific Exposures) in the Solvency II delegated regulation EU/2015/35 it does not entirely exclude exposures from the calculation of the market risk concentration (as for example might be the case under article 184.2) but instead seems to alter some of the input used in articles 184.1, 185 or 186 when calculating the SCR for each individual counterparty exposure in the concentration risk module in the market risk SCR; As we read Article 400, however, this article instead would seem to state that certain large positions should be excluded from the risk calculations? Other more specific queries that arise as a result of the reference made to Article 187 are: • Whether EIOPA intended that the “exemptions” should cover all subparagraphs of article 187 (1-5) or only a subset of them? To exemplify this query – article 187.2 states that immovable properties are assigned a relative excess exposure threshold CT i of 10 % and a risk factor g i for market risk concentration of 12 %. When calculating the exemptions in C0320, are we then comparing the impact for the market concentration risk module, if we apply instead the standard input in the above-mentioned articles? • If it is more specifically subparagraph 187.3 that is intended - exposures shall be assigned a risk factor g i for market risk concentration of 0 % - When calculating the exemptions in C0320 should we exclude the entire value of the exposure or again compare the impact for the market concentration risk module if we apply instead the standard input in the above-mentioned articles for said exposure? Your clarifications to the above would be appreciated.