In accordance with point (2)(c) of Article 4(1), certain entities are excluded from the definition of investment firm. Since Regulation (EU) 575/2013 is applicable to investment firms it follows that those entities are not within the scope of that Regulation. The only exception to this is Article 95(2), where those entities are explicitly scoped in for the purpose of the calculation of own funds requirements. Where a Member State wishes to subject those entities to requirements other than own funds requirements, such as reporting, it has to do so through national legislation.
This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate General of the Commission (Directorate General for Internal Market and Services) has prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.