Question ID
2026_7739
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
Z 09.04 FMI 4
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
Article/Paragraph
Z 09.04 FMI 4
Type of submitter
Credit institution
Subject matter
II.29 Z 09.04 - FMI Services – CCPs – Alternative Providers (FMI 4)
Question

According to c0050 "ID alternative provider" definition it looks like the entity should only report Alternative Provider when these providers are already reported in Z09.01.
In the case an entity has a contingent contract of substitution with an alternative provider which currently doesn't provide any services to the entity, should the entity report this alternative provider? In affirmative case, which c0050 ID should we provide?

Background on the question
Columns  Instructions 
0010

ID representing combination of user, FMI, system type and intermediary

Identifier of the CCP as provided in Z 09.01, column 0010. 

Only report for CCPs accessed either directly or indirectly. Report all accesses to CCPs.
0020

Product Type

Product type covered by the clearing agreement. Report at appropriate level of granularity needed for the substitutability analysis.
0030

Substitutability Y/N

Ability of User to replace the clearing service provider in Z 09.01 column 0020 with an alternative FMI/intermediary with which it has a contractual relationship at the reporting date. .

  • ‘Yes’ if substitution is possible

  • ‘No’ if substitution is not possible

 
0040

Alternative Provider

Name of FMI/intermediary identified as potential substitute. 

Report only if Z 09.04 column 0030 is Yes.
0050

ID alternative provider

Unique ID representing combination of user, FMI, system type and intermediary of the Alternative Provider with which the User has an established contractual relationship as reported in Z 09.01 column 0010. 

Report only if Z 09.04 column 0030 is Yes.
Submission date
Final publishing date
Final answer

According to the instructions of the Annex on IT solutions, template Z_09.04 should be filled in with regard to alternative providers that are CCPs.  

Alternative Providers must be reported in Z 09.01 only if there is an established contractual relationship with them and, in line with the instructions in c0020 “Entity name”, the service is used.  

Should the reporting entity not have an established contractual relationship with the alternative provider and should it not use the service, the alternative provider does not need to reported in Z 09.01 and Z 09.04. 

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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