Single Rulebook Q&A

Question ID: 2016_2801
Legal act : Regulation (EU) No 575/2013 (CRR)
Topic : Supervisory reporting
Article: 415
Paragraph: 3
Subparagraph: b
Article/Paragraph : Annex XIX, part 1.3, template C 68.00, all rows
COM Delegated or Implementing Acts/EBA RTS/EBA ITS/EBA GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Name of institution: Banco de España
Country of incorporation / residence: Spain
Subject matter : Difference between 'product type' and 'product category' and clarification on product type reporting (Annex XIX, part 1.3, template C 68.00)

Template C 68.00 seeks to collect information about the reporting institutions' concentration of funding by product type, broken down into the listed funding types. After giving a broken-down list of funding types, the ITS in point 1.3.2 establishes that ‘for the purpose of completing this template, institutions shall report the total amount of funding received from each product category, which exceeds a threshold of 1 % of total liabilities’.

Later, in point 1.3.4 the ITS states that ‘for the purpose of determining those product types from which funding obtained is greater than 1% of total liabilities threshold, the currency is irrelevant’.

The doubt arises because in point 1.3.2, the ITS talks about ‘product category whereas in point 1.3.4 and also in the rest of the template, the ITS uses ‘product types’. Although the spirit of the regulation may suggest that both refer to the same concept, it is not clear that ‘product category’ and ‘product type’ can be considered interchangeable and have the same meaning.

In either case, some clarification is needed.

1)     Therefore, what does the ITS mean by ‘product category’? Would it be the same meaning as ‘product type’? In either case, a complete description of what is understood as ‘product type’ or ‘product category’ would be helpful.

2)     In this line, and assuming that product type and product category are the same, then, each row of template C 68.00 would be considered a different product type / product category?
If so, are they exclusionary?
If they are, what are the concepts that have priority?
For instance, if we have an unsecured wholesale funding that is both i) of which financial customers and ii) of which from intra-group entities, under which type should it be reported?

Background on the question:

see above

Date of submission: 22/06/2016
Published as Final Q&A: 12/01/2018
EBA answer:

Template C 68.00 of Annex XVIII to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) gathers information on the most relevant sources of funding for the institutions. Therewith they are required to report the outstanding amount of the funding in terms of carrying value for each product type indicated in the template that is greater than 1% of the total liabilities.


The product type refers to the products listed in paragraph 1 of chapter 1.3 of Annex XIX to the ITS on Supervisory Reporting.


The sub categories listed under e.g. product type ‘wholesale funding, unsecured wholesale funding’ are not exclusionary. See also Q&A 2015_1949.

Status: Final Q&A
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