When following guidance found in AnnexII (page 185-190) there is no guidance as to where to include Commodity Assets (or liabilities) that are not derivatives (even though they are in scope for PVA threshold assessment). These are not Financial Assets or Liabilities even if fair valued and as such do not fit in any of the rows on the template. The equivalent row for assets in Finrep template 01.01 is row 360 'Other assets' but this has no equivalent in template C32.01.
see question above
Annex II of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) defines fair-valued assets and liabilities in template C32.01 as “absolute value of fair-valued assets and liabilities, as stated in the financial statements under the applicable accounting framework, as referred to in Article 4(1) of the Delegated Regulation (EU) 2016/101 on prudent valuation, before any deduction pursuant to Article 4(2) is performed.”. Additionally, The definitions of these categories shall match those of the corresponding rows of FINREP templates 1.1 and 1.2.
Additionally, Article 2(a) of the Delegated Regulation (EU) 2016/101 uses the following definition: ‘valuation position’ means a financial instrument or commodity or portfolio of financial instruments or commodities held in both trading and non-trading books, which are measured at fair value;
Annex V part 2 Article 1.1.5 of ITS mentions “Assets that are not financial assets and that due to their nature could not be classified in specific balance sheet items shall be reported in ‘Other assets’. Other assets shall include, among others, gold, silver and other commodities, even where they are held with trading intent.”
Hence, template C32.01 shall be extended to include a row for Other assets and a row for Other liabilities, to capture commodities as well as other residual assets or liabilities (e.g. assets or liabilities Held for Sale) under the scope of template C32.01 but that cannot be captured by the existing breakdown.
As an interim solution, these items shall be included in 'Total fair-valued assets ' and 'Total fair-valued liabilities '.