According to the instructions on C 33.00, the column c0020 ('Total carrying amount of non-derivative financial assets (net of short positions)') should be reported this way:

'Aggregate of the carrying amount, in accordance with paragraph 27 in Annex V, Part 1, of non-derivative financial assets to General governments for all accounting portfolios under IFRS or national GAAP based on BAD defined in paragraphs 15 to 22 in Annex V, Part 1 and listed in columns 0030 to 0120, net of short positions.

When the institution has a short position for the same residual maturity and for the same immediate counterparty (...), the carrying amount of the short position shall be netted against the carrying amount of the direct position. This net amount shall be considered as zero when it is a negative amount. (...)'

In this regard, two questions arise regarding column 0020:

• Are the instructions correct and do we have to report always column 0020 as the as the sum of the columns 0030 to 0120 minus column 0130 with independence of the counterparty and/or maturity of the short position?
• Should we report 0 in column 0020 when the net position is negative? 

It’s relevant to clarify these issues because the definition affects to validations v10651_m and v5853_h.

v10651_m

c[0010, 0020, 0030, 0040, 0050, 0060, 0070, 0080, 0090, 0100, 0110, 0120, 0130, 0140, 0150, 0160, 0170, 0180, 0190, 0200, 0210, 0220, 0230, 0240, 0250, 0260], z1:* : {r0010} = {r0170} + {r0180} + {r0190} + {r0200} + {r0210} + {r0220} + {r0230}

We cannot fulfill this validation for column 0020 since it is the sum of column 0030 to 0120 and netted with 0130, if this result is negative we have to report a 0 (it does not allow us to report negative values). In this case, in that column the equality cannot be fulfilled.

v5853_h

c[0010, 0020, 0030, 0040, 0050, 0060, 0070, 0080, 0090, 0100, 0110, 0120, 0130, 0140, 0200, 0210, 0220, 0230, 0240, 0250, 0260, 0290, 0300], z1:* : {r0010} >= {r0020}

For all the columns row 0010 must be greater than row 0020. In this regard, the same issue arises in column 0020. When we net row by row, row 010 should be reported as 0 if the net value is negative and therefore the validation does not work in this case.

Example

Please consider the following example:

• Column 0030: Long position, amount 1000 euros, residual maturity 6 months
• Column 0130: Short position, amount 1000 euros, residual maturity 3 months

If we report column 0020 as Column 0030 minuss column 0130, the amount to be reported in column 0020 is equal to 0, is this correct? If we report a figure equal to 0, we can be netting exposures with different residual maturities and/or different counterparties. Note also that the amount reported in column c020 by exposure class (0) will be different from the breakdown by residual maturity (0 in the bucket until 3 months and long position of 1000 in the bucket 3m to 1 year).