Should r010, c300 of template C 08.01 be additive for number of obligors e.g. a retail Customer has 3 exposures in different obligor grades, 2 are On Balance sheet and 1 is Off Balance sheet. In template C 08.02 this would be disclosed as 3 obligors given that they are included within 3 different grades. In templates C 08.01 should this customer then be disclosed as 3 obligors in r010, c300 or 1 obligor?
Guidance is provided for template C08.02 for obligors, but no guidance for how obligors in template C08.01 correspond to template C08.02
Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), Annex II, chapter 3.3.3.1, column 300 (template C 08.01), states that:
‘Within the exposure class retail the institution shall report the number of exposures which were separately assigned to a certain rating grade or pool. In case Article 172 (2) of CRR applies, an obligor may be considered in more than one grade.’
Therefore, where the institution assigns ratings at exposure level and not at obligor level within the exposures class ‘retail’, the total number of exposures shall be reported in row 010, column 300 of template C 08.01.
For the example mentioned in the question, this means:
Total exposures: {C 08.01, r010, c300} = 3 for the respective sheets,
On balance sheet items: {C 08.01, r020, c300} = 2 for the respective sheets,
Off balance sheet items: {C 08.01, r030, c300} = 1 for the respective sheets.