What is the exact meaning of net long and net short position for the purpose of columns 030 and 040 ( 18net positions long / short 19) in template C 21.00 (MKR SA EQU)?

The instructions on columns 030 and 040 of template C 21.00 refer to Articles 327, 329, 332, 341 and 345 of CRR without providing further explanations. Therefore it is not clear whether these references shall mean a) respectively the sum of net long positions and net short positions according to Article 327 (as mentioned both in Article 341 (1) and (2) CRR) or b) the overall net position as defined in Article 341 (2) CRR. In our opinion, solution a), i.e. the sum of net long positions and net short positions according to Article 327 (as mentioned both in Article 341 (1) and (2) CRR), should be reported for the following reasons. For general risk (rows 020 13 040 of C 21.00), the overall net position is always reported in column 050 ( 18positions subject to capital charge 19). The only benefit of having the overall net positions shown also in column 030 / 040 would be to know if it is an overall net long position or an overall net short position. In contrast, showing the sum of net long positions and net short positions respectively in columns 030 and 040 instead would provide more detailed information on the institutions 19 risk position and would allow to double-check the calculation of own funds requirements. For specific risk (row 050 of C 21.00), having the sum of net long positions and net short positions is essential. Otherwise the process of calculating own funds requirements would not be represented correctly in the template (as 13 in opposition to own funds requirements for general risk 13 own funds requirements for specific risk cannot be derived from the gross positions shown in columns 010 and 020 of C 21.00). For the particular approach for position risk in CIUs (row 080 of C 21.00), showing the sum of net long positions and net short positions is also essential to backtrace the calculation of own funds requirements.

In template C 21.00 of Annex I of Regulation (EU) No 680/2014 - ITS on reporting, in columns 030 and 040 ('net positions long/short') the sum of net long position (c030) and the sum of net short positions (c040) according to Article 327 CRR shall be reported. This is in line with Article 341 (1) and (2) CRR.