From our point of view, Annex II of the ITS on Supervisory Reporting of Institutions does not clearly indicate the reporting requirement of C34.01. The description of the columns and rows is based on Article 273a CRR. According to this, if the methods set out in Section 4 or 5 of Chapter 6 of Title II of Part Three CRR are not applied, we would assume that no reporting of the reporting form should take place.

However, this is contradicted by the last sub-sentence of point 122 of Annex II, which states "...and, more generally, important information on the size of the derivative business." in conjunction with question 18 from the Final draft ITS on Supervisory Reporting of Institutions. Response of EBA to Question 18: “As this template provides important information on the overall size of the derivative business, which is relevant for all institutions and not available in other reports, the EBA considers the template relevant for all institutions with CCR business. … ”

Thus, in our view, it is unclear whether there is a reporting requirement for institutions that have CCR exposures that are not covered by the methods set out in Section 4 or 5 of Chapter 6 of Title II of Part Three CRR.