With reference to Resolution Reporting on FMI Services, we would like to bring to your attention some questions regarding the scope and data reported, particularly in cases where the Bank participates indirectly in certain FMIs.
With reference to item "Z 09.03 - Financial Market Infrastructure Services (FMI) - Key Metrics (FMI 3)", we would therefore like to know whether, for FMIs to which we participate indirectly, it is possible to report intermediary data instead of individual FMI data, and, if so, how to complete the individual items. The question specifically concerns the following reporting fields:
• Z 09.03/60-70 Value of positions on proprietary and client accounts
• Z 09.03/80 Number of clients covered by omnibus accounts
• Z 09.03/90 Number of clients covered by segregated accounts
• Z 09.03/100-110 Number of transactions on proprietary and client accounts
• Z 09.03/120-130 Value of transactions on proprietary and client accounts
This requirement arises from the fact that, since we use an intermediary, we do not have internal evidence of the final FMIs on which it relies. In fact, our systems only map the intermediary's reference, while the references of the final FMIs are not tracked.
As an example, we can cite Intesa San Paolo, which acts as an intermediary for Banca Mediolanum on all CSDs and most trading venues. In our systems, Intesa San Paolo is matched to all securities transactions, without specifying the final CSD.
We currently report that we are still providing the above-mentioned information by requesting detailed data from our intermediaries. In this regard, we also note that our intermediaries will include our data in their reporting for individual FMIs, reporting us as their clients in these contexts.
Finally, we would like to take this opportunity to request clarification regarding some new items introduced starting this year, specifically:
• Z 09.01/80 Operator of the FMI - is it correct to indicate the contractual contact person of the FMI/Intermediary?
• Z 09.04/20 Product Type - Is it possible to include a description of the service provided by the FMI/intermediary, consistent with that indicated in item Z 09.01/220 - Services provided by FMI/intermediary, possibly with greater detail?
• Z 09.04/30 Substitutability - Should the substitutability analysis be performed for all FMIs, considering as alternative FMIs/intermediaries only those with which a contract at the conglomerate level is already in place?
- Legal act: Directive 2014/59/EU (BRRD)
- COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
