Question
Field 100 - Compliance with the Retention Requirement?. How do we report for Investor positions originated prior to 2011?
Background on the question
Article 404 of the CRR states that "Titles II and III shall apply to new securitisations issued on or after 1 January 2011". Article 405, which falls within Title II, is the retention requirement ruling. What do we therefore report in this field for Investor positions held which were issued prior to 2011?
Answer
The instructions in Annex II of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions for column 100 "COMPLIANCE WITH THE RETENTION REQUIREMENT?" of C 14.00 Template (CR SEC Details) state that this column shall not be reported in case code 'N' (not applicable) is reported under column 080 (Type of retention applied). This code refers to securitisations affected by the provisions of Article 404 of the Regulation (EU) No. 575/2013 (CRR).