EBA validation v7349_m prescribes that C_14.00 column c0140 should be smaller of equal to the sum of c0230+c0240+c0250. There three columns only relate to on-balance positions. Off-balance positions are not considered in this validation. For our sponsored ABCP transactions this results in a validation breach. We also noticed that this validation was deactivated in DPM 4.0 and no (without changes) reactivated in DPM 4.2. 

We propose to change this validation rule form:

v7349_m: with {tC_14.00, default: 0, interval: true}: {c0140} <= {c0230} + {c0240} + {c0250}

to:

v7349_m: with {tC_14.00, default: 0, interval: true}: {c0140} <= {c0230} + {c0240} + {c0250} + {c0260} + {c0270} + {c0280}

Like this off-balance positions are also included.