Is there a mistake in the Validation formula v4448_m and in the corresponding statement in the ITS?

Validation formula v4448_m states that : {C43.00.A, r010, c010} = sum({C47.00, c010, (r150-180)} Likewise, the same equation is presented in ITS (EU) 2016/ 428 in {C43.00, c010, r010}.

However, we think that the equation is not true because: On the one hand, intragroup exposures ARE NOT included in {C43.00, r010,c010} (please see C43.00 paragraph 8 point 28 on page L83/38 referring to {LRCalc 250;010} where the amount of intragroup exposures that can be exempted is reported). On the other hand, intragroup exposures ARE included in the sum of {LRCalc r150-180} according to C47.00 paragraph 4 point 19 on page L83/17.

According to Article 429(7) of the Regulation (EU) No 575/2013 (CRR), as amended by Regulation (EU) 2015/62, competent authorities may permit an institution not to include in the leverage ratio exposure measure exposures that can benefit from the treatment laid down in Article 113(6) of the CRR.

While institutions shall report the leverage ratio exposure values in template C 43.00 of Annex X of Regulation (EU) No 680/2014 as amended by Regulation (EU) 2016/428 (amended ITS on Supervisory Reporting) after the application of certain exemptions, including the exemption laid down in Article 429(7) CRR (see Part II, paragraph 28 of Annex XI to the amended ITS on Supervisory Reporting), institutions have to report the exposures in {C47.00;r150-180;c010} without taking into account the above mentioned privileged treatment of intragroup exposures since those adjustments are shown in a separate row ({C47.00;r250;010}).

Against this background, the comment is correct and validation rule v4448_m will be corrected as soon as possible. Furthermore, the formula in the instructions for {C43.00;r010;c010} will be amended in the next available version of the ITS on Supervisory Reporting in order to exclude the off balance sheet items which are subject to the exemption according to Article 429(7) CRR.