What is the correct interpretation of instrument No.40?
The description of instrument 40 is ambiguous. The booking of a normal FX Spot trade with a standard delivery date of T+2 (== 21.09.2018) – a possible interpretation of the ITS instructions – results in an IMV value of zero as the trade has already matured on the IMV date.
With regard to Instruments 40, section 2, Annex 5 of the Regulation (EU) 2016/2070 - ITS on Supervisory Reporting,
for the exercise 2019, the instruments has to be considered as 1 million USD cash (long position, to be reported in Euro). The long cash position of USD 1 million should be booked on the booking date. The cash position should continue to exist throughout the exercise and not mature prematurely (whereas an FX spot purchase would mature at delivery). For IMV purposes, institutions should report the market value of the long cash position of USD 1 million in the base currency of the instrument, i.e. EUR.
Update 03.12.2021: This Q&A has been updated in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking.