Please check the appropriateness of validation rule (v3995_u) "{C 27.00, c010} is a row identifier, and must be unique for each row in the table"

In the case of a group of connected clients an institution should fulfil the LE1 template for the group of connected clients and for all individual clients forming a group. The instructions (LE1 template) define that: "The code of a group corresponds to the code of a parent in this group". Consequently a client in a group (parent) and the group have the same code. Therefore is validation rule "{C 27.00, c010} is a row identifier, and must be unique for each row in the table" not logical and it does not allow correct reporting of groups of connected clients.

Validation Rule v3995_u is correct and needs to be fulfilled, even if this validation rule is not part of Annex XV of the Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS). Otherwise the data points would not be unique and could not be reported.

According to the instructions in Annex IX of the ITS for C 27.00 Template (LE1) row 010, the parent, or in its absence the most significant entity of the group, and the group of connected clients have the same code. In addition the instructions for rows 010-070 say that any counterparty, for which information is being submitted should be reported.

This inconsistency can be solved by requiring that only the information regarding each individual counterparty is reported in the C 27.00 Template. The identification of the group of connected clients shall not be reported in the C 27.00 Template, unless the national reporting system provides a unique code for the group of connected clients.

The instructions will be amended accordingly.