Third party investment products distributed by an institution should be reported under “Assets Management” (F 22.02, r0010, c0010), “Custody Assets” (F 22.02, r0060, c0010) or “Customer resources distributed but not managed” (F 22.02, r0130, c0010)?

An institution has a strategic partnership with an external provider of equity and bond funds, and sells the products of this external provider (e.g. CIUs, funds or life insurance policies which are promoted by specialised asset management companies or insurance companies) within its network. The institution categorizes these assets as under management in its financial statement because, when distributing these products, consultancy and advisory are provided to the customers, and therefore this activity is distinguished from mere custody. For the purpose of reporting in FINREP template F 22.02 though, it is not clear how to interpret the reporting instruction to determine the allocation of such assets across the different rows.

As they are not managed by the reporting institution, the products cannot be categorized in “Assets management” (row 0010 of F 22.02). As they are distributed by the reporting institution, they cannot either be categorized merely as “Custody”,
The products should be reported as “Customer resources distributed but not managed” (F 22.02, r0130, c0010).