The last two sentences of paragraph 127 (General Remarks on template C 18.00 – MKR SA TDI) of the ITS on Supervisory Reporting (Annex II) state the following: ‘The specific risk associated with exposures included in MKR SA SEC (i.e C 19.00) and MKR SA CTP (i.e. C 20.00) only has to be reported in the Total template of the MKR SA TDI (i.e. C 18.00). The own funds requirements reported in those templates shall be transferred to cell {325;060} (securitisations) and {330;060} (CTP) respectively.’
The problem is that, if the guidance above guidance is anything to go by, then cell {325;060} (securitisations) and {330;060} (CTP) respectively should be greyed out in MKR SA TDI (i.e. C 18.00) on all the currency sheets s002 - s026, meaning they should never be populated and the validation rule v6019_m should always fail.
However, the currency sheets s002 to s026 of the C 18.00 do not reflect the general remarks guidance in the ITS on Supervisory Reporting (Annex II) for C 18.00, as cell {325;060} (securitisations) and {330;060} (CTP) respectively have not been greyed out, have data point IDs and can actually populated. This means that the validation rule e v6019_m, despite not being consistent with the guidance in the ITS should always pass.
In summary the general remarks for template C 18.00 in the ITS on Supervisory Reporting (Annex II) is not consistent with the formatting of the currency analysis sheets s002 to s026 of the same template C 18.00 (MKR SA TDI).