Are the columns 040-070 memorandum items in the same way (the figure should be reported where the obligors would have been reported if those exposures were not in assigned to “in default”) that column 020 is?
Row 100 “Exposures in default” are grey marked and therefore not possible to fill in. The requested information in column 040-070 is in addition mostly referable to defaulted exposures. Column 020 has a clearification in Annex II that it is a memorandum item and that the exposures should be reported in the exposure classes they would have been assigned to if not in default. This information does not exist for columns 040-070. It is logical to assume that columns 040-070 should be treated in the same way as column 020 based on way the template is designed, even if this is not written in the instruction.
The concept of columns 020, 040 and 070 in C 09.01 is different from the concept of columns 050 to 060. This is also reflected in the DPM (table C 09.01 b in the DPM).
To represent correctly the different concepts, the grey shading of cells 100/050 to 100/060 will be deleted in the next revision of the ITS on Supervisory Reporting.