Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Annex III, F 22.02
Disclose name of institution / entity:
Type of submitter:
Accounting firm
Subject Matter:
Reporting of Off Balance Sheet Activities (Table 22.2)

If the reporting entity has the same assets under asset management and also under its custody, can the assets reported in sub-sections of table 22.2 (e.g. ‘Custody assets’, ‘Asset Management’, and ‘Central administrative services for collective investment’) be duplicated?

Background on the question:

For example, the assets of a mutual fund X - fund assets may be reported as ‘Collective investment’ (row 020) within Asset Management, as well as ‘Collective investment’ (row 070), and ‘Of which: entrusted to other entities’ (row 090) within Custody assets section in table 22.2, if the custody of fund X assets is held with a sub-custodian.

Date of submission:
Published as Final Q&A:
Final Answer:

The categories of the breakdown in F 22.02 are not exclusive, which means that assets shall not be necessarily allocated into one category. Actually, this breakdown does not have a total, calculated as the addition of the categories lower in the hierarchy.

Therefore, in the event that the reporting entity has the same assets under its management and under its custody, it shall report them twice in F 22.02, once as belonging to the category "asset management " and also under "custody assets". In the case of custody assets held by a "sub-custodian", they shall also be reported under "of which, entrusted to other entities".

It is important to note that for the same asset to be allocated to more than one category, the reporting entity must ensure that they come within the definitions of the categories in paragraph 117 of Part 2 of Annex V of the Regulation (EU) No 680/2014 13 ITS on supervisory reporting of institutionsDraft ITS on Supervisory reporting.


*As of 1/8/2014 the content of this answer was modified to reflect the publication of the final ITS on supervisory reporting of institutions in the Official Journal of the European Union. As a result, the references to the ITS were updated and the disclaimer deleted. For reasons of transparency, revisions are highlighted in track changes.

Final Q&A
Answer prepared by:
Answer prepared by the EBA.