Can you please confirm that the memorandum items in row 290-320 only should be filled in within exposure classes mentioned under point 54 (annex II, 3.2.1) and the Total template? I.e. that those rows should be empty in the exposure classes “in default” and "secured by immovable property”.
The memorandum items in C07.00 should, according to point 54 and 56 in the instruction, only be reported in the six exposure classes that are specified. Exposure class “in default” is not mentioned among those six exposure classes. However, in the example in point 57 it is written that row 220 (which is one of the rows in the memorandum items: “exposures secured by mortgages on commercial immovable property”) should be filled in on row 220 both in exposure class “Institution” as in exposure class “in default”. This seems contradictory to point 54 and 56.
As explained in paragraph 54 of the CR SA instructions (Annex II, 3.2.2 of the
Draft ITS on Supervisory reporting), the memorandum items shall only be reported for the 6 exposure classes: 'Central governments or central banks ', 'Regional governments or local authorities ', 'Public sector entities ', 'Institutions ', 'Corporates ' and 'Retail '. They shall also be reported in the CR SA total template. Memorandum items rows should be empty in the exposure classes "in default " and "secured by immovable property ".
*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.