The instructions for columns 0447 and 0448 of COREP template C 14.01 (Memorandum items – Risk-weighted exposure amount under SEC-ERBA and Risk-weighted exposure amount under SEC-SA) do not provide specific guidance on the cases where reporting is expected, creating uncertainty on how the obligation to report the amount in columns 0447 and 0448 should be interpreted. In particular is it mandatory to report these memorandum columns whenever it is applicable and they can be calculated or only when it is specifically implied in the legislation that the reporter is expected to compute the amount under a different method as well to comply with regulatory provisions (e.g in accordance with the Articles 254(2)(a), 254(2)(b) of the CRR, to also calculate the amount under SEC-SA for transactions reported under SEC-ERBA)?

In general, the presence of the memorandum items in the template implies an obligation to compute and report the respective datapoints, when applicable. On the other hand, an obligation to compute risk-weighted exposure amounts according to a different method compared to the one applied for regulatory purposes could be seen as going beyond the scope of the ITS on Supervisory Reporting.