For the COREP C17.01 template, in the ANNEX II INSTRUCTIONS FOR REPORTING ON OWN FUNDS AND OWN FUNDS RE-QUIREMENTS document, section 4.2. Operational Risk: Detailed information on losses in the last year (OPR DETAILS), paragraph 149 appears to clarify that banks should only report losses where the net impact over last 10 years exceeds the threshold. However, this appears to contradict with later section “4.2.2.2.     Instructions concerning specific positions”, explaining events that should have been reported previously, with gross loss over all periods exceeding threshold. We would like to ask for clarification in this case, shall we consider only impacts in the last 10 years with net loss that exceeds the threshold or consider all history for the particular event (from 2008).