We have noticed that there is no code for Croatian currency (HRK) as pre-defined separate reporting currency in templates C18 and C22 and no code for Croatian market as pre-defined separate reporting market in template C21.

Throughout templates C18 and C22 (market risk – standardised approach) there is no special code for Croatian currency as separate reporting currency, therefore HRK exposures (most significant exposures in Croatian banks) are included in one residual template together with all other residual currencies. That kind of treatment of HRK positions is not satisfactory from our point of view because it leaves our reports without separate information on major positions. Similarly, in template C21 (market risk - standardised approach) Croatian market is not designated as pre-defined separate market (most significant market in Croatian banks) but is to be included for reporting purposes together with positions held on all other markets. As Croatia is a member of EU, we believe that codes for our market and our currency should be listed in above mentioned reports, even more because codes for some non-EU countries are listed in these reports.

C 18.00 and C 22.00 Templates should also include the Croatian currency (HRK) as well as C 21.00 Croatia as separate market.

The templates will be amended accordingly in the next available version of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions.