Commission Implementing Regulation (EU) 2021/2284 of 10 December 2021 laying down implementing technical standards for the application of Regulation (EU) 2019/2033 of the European Parliament and of the Council with regard to supervisory reporting and disclosures of investment firmsText with EEA relevance.

Commission Implementing Regulation (EU) 2021/2284 of 10 December 2021 laying down implementing technical standards for the application of Regulation (EU) 2019/2033 of the European Parliament and of the Council with regard to supervisory reporting and disclosures of investment firms (Text with EEA relevance) THE EUROPEAN COMMISSION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Regulation (EU) 2019/2033 of the European Parliament and of the Council of 27 November 2019 on the prudential requirements for investment firms and amending Regulations (EU) No 1093/2010, (EU) No 575/2013, (EU) No 600/2014 and (EU) No 806/2014 OJ L 314, 5.12.2019, p. 1. , and in particular Article 49(2) and Article 54(3) thereof, Whereas: (1) The reporting requirements for investment firms provided in Article 54 of Regulation (EU) 2019/2033 should be tailored to the business of the investment firms and be proportionate to the scale and complexity of different investment firms. Those requirements should in particular take into account that certain investment firms are to be considered to be small and non-interconnected as per the conditions set out in Article 12 of Regulation (EU) 2019/2033. (2) According to Article 54(1) of Regulation (EU) 2019/2033, small and non-interconnected investment firms are to report information about the level and composition of their own funds, their own funds requirements, the basis for the calculation of their own funds requirements and the level of activity in respect of the conditions set out in Article 12(1) of Regulation (EU) 2019/2033. Small and non-interconnected firms are thus not required to report the same level of detail of information as other investment firms subject to Regulation (EU) 2019/2033. The reporting templates on K-factor calculation should therefore not be applicable to small and non-interconnected firms. In addition, according to Article 54(2), third subparagraph, of Regulation (EU) 2019/2033, small and non-interconnected firms are exempt from reporting on concentration risk and competent authorities may exempt small and non-interconnected firms from the obligation to report on liquidity requirements. (3) All investment firms subject to Regulation (EU) 2019/2033 should report their activity profile and size to enable competent authorities to assess whether those investment firms meet the conditions laid down in Article 12 of Regulation (EU) 2019/2033 to be classified as small and non-interconnected investment firms. (4) In order to provide transparency to their investors and the wider markets, Article 46 of Regulation (EU) 2019/2033 requires investment firms other than small and non-interconnected investment firms to publicly disclose the information specified in Part Six of that Regulation. Small and non-interconnected investment firms are not subject to those disclosure requirements, except where they issue Additional Tier 1 instruments in order to provide transparency to the investors in those instruments.

(5) This Regulation should provide investment firms with templates and tables to convey sufficiently comprehensive and comparable information on the composition and quality of their own funds. More specifically, it is necessary to introduce a quantitative disclosure template on the composition of own funds and a flexible template on the reconciliation of regulatory own funds with the audited financial statements. For the same reason, it is also necessary to lay down a template with information on the most relevant features of own funds instruments issued by the investment firm. (6) In order to facilitate the implementation of reporting and disclosure requirements, it is necessary to enhance the consistency between reporting and disclosure templates. The template for the disclosure on composition of own funds should therefore be closely aligned with the related reporting template on the level and composition of own funds. For the same reason, the template for the disclosure on full reconciliation of own funds with the audited financial statements should be flexible in that the breakdown of the template should be based on the breakdown of the balance sheet in the investment firm’s audited financial statements. Additionally, the template to disclose information about the main features of regulatory own funds should be a fixed template and its complexity should depend on the complexity of the own funds instruments. (7) To ensure that compliance costs for investment firms are not unreasonably increased and that data quality is maintained, reporting and disclosure obligations should be aligned in their substance to the maximum extent possible with each other. It is therefore appropriate to set out, in a single Regulation, standards applicable to both reporting and disclosure requirements. (8) This Regulation is based on the draft implementing technical standards submitted to the Commission by the European Banking Authority (EBA) after having consulted the European Securities and Markets Authority. (9) The EBA has conducted open public consultations on the draft implementing technical standards on which this Regulation is based, analysed the potential related costs and benefits and requested the advice of the Banking Stakeholder Group established in accordance with Article 37 of Regulation (EU) No 1093/2010 of the European Parliament and of the Council Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Banking Authority), amending Decision No 716/2009/EC and repealing Commission Decision 2009/78/EC (OJ L 331, 15.12.2010, p. 12). , HAS ADOPTED THIS REGULATION: CHAPTER I SUPERVISORY REPORTING

Article 1

Reporting reference dates

1. The information referred to in Article 54(1) of Regulation shall be reported as this information stands on the following reporting reference dates: (a) quarterly reporting: 31 March, 30 June, 30 September and 31 December; (b) annual reporting: 31 December.

1. The reporting reference dates referred to in paragraph 1 may be adjusted where investment firms are permitted by national law to report their financial information based on their accounting year-end which deviates from the calendar year, so that the quarterly reporting of information is performed every three months of the respective accounting year and the annual reporting at the accounting year-end.

Article 2

Reporting remittance dates

1. The information referred to in Article 54(1) of Regulation (EU) 2019/2033 shall be submitted by close of business of the following remittance dates: (a) quarterly reporting: 12 May, 11 August, 11 November and 11 February; (b) annual reporting: 11 February.
2. Where the reporting remittance day is a public holiday in the Member State of the competent authority to which the report is to be provided, or a Saturday or a Sunday, the reporting remittance day shall be the following working day.
3. Where investment firms report their information using adjusted reporting reference dates based on their accounting year-end as set out in Article 1(2) of this Regulation, the remittance dates may be adjusted accordingly so that the same remittance period from the adjusted reporting reference date is maintained.
4. Investment firms may submit unaudited figures. Where audited figures deviate from submitted unaudited figures, the revised, audited figures shall be submitted without undue delay. For the purposes of this Article, unaudited figures shall mean figures that have not received an external auditor’s opinion whereas audited figures are figures audited by an external auditor expressing an audit opinion.
5. Corrections to the submitted reports shall be submitted to the competent authorities without undue delay.

Article 3

Application of reporting requirements on an individual basis In order to comply with the reporting requirements of Article 54 of Regulation (EU) 2019/2033 on an individual basis, investment firms shall report the information specified in Articles 5, 6 and 7 of this Regulation with the frequency specified therein.

Article 4

Application of reporting requirements on a consolidated basis In order to comply with the reporting requirements referred to in Article 54 of Regulation (EU) 2019/2033 on a consolidated basis, investment firms shall report the information specified in Articles 5 and 6 of this Implementing Regulation with the frequency specified therein.

Article 5

Format and frequency of reporting by investment firms other than small and non-interconnected investment firms

1. Investment firms other than small and non-interconnected investment firms shall report the information required by paragraphs 1 and 2 of Article 54 of Regulation (EU) 2019/2033 by using the templates laid down in Annex I to this Regulation in accordance with the instructions set out in Annex II to this Regulation with a quarterly frequency.
2. Investment firms other than small and non-interconnected investment firms that determine the RtM K-factor requirement on the basis of K-NPR in accordance with Article 21(1) of Regulation (EU) 2019/2033 shall report the information specified in templates C 18.00 to C 24.00 of Annex I to Commission Implementing Regulation (EU) 2021/451

Commission Implementing Regulation (EU) 2021/451 of 17 December 2020 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to supervisory reporting of institutions and repealing Implementing Regulation (EU) No 680/2014 (OJ L 97, 19.3.2021, p. 1). in accordance with the instructions set out in Part 2 of Annex II to that Implementing Regulation with a quarterly frequency. 3. Investment firms other than small and non-interconnected investment firms that make use of the derogation laid down in Article 25(4) of Regulation (EU) 2019/2033 shall report the information specified in template C 34.02 of Annex I to Implementing Regulation (EU) 2021/451 in accordance with the instructions set out in Part 2 of Annex II to that Implementing Regulation with a quarterly frequency. 4. Investment firms other than small and non-interconnected investment firms that make use of the derogation laid down in Article 25(5), second subparagraph, of Regulation (EU) 2019/2033 shall report the information specified in template C 25.00 of Annex I to Implementing Regulation (EU) 2021/451 in accordance with the instructions set out in Part 2 of Annex II to that Implementing Regulation with a quarterly frequency.

Article 6

Format and frequency of reporting by small and non-interconnected investment firms

1. Small and non-interconnected investment firms shall report the information specified in the templates of Annex III to this Regulation in accordance with the instructions of Annex IV to this Regulation with an annual frequency. Investment firms that benefit from the exemption referred to in Article 43(1), second subparagraph, of Regulation (EU) 2019/2033 shall be exempted from the duty to submit the information specified in template IF 09.01 of Annex III to this Regulation.

Article 7

Format and frequency of reporting by entities benefitting from the application of Article 8 of Regulation (EU) 2019/2033 By way of derogation from Article 4 of this Regulation, entities referred to in Article 8(3) of Regulation (EU) 2019/2033 that are benefitting from the application of that Article shall report the information set out in the templates of Annex VIII to this Regulation in accordance with the instructions set out in Annex IX to this Regulation with a quarterly frequency.

Article 8

Data precision and information associated with submissions

1. Investment firms shall submit the information referred to in this Regulation in the data exchange formats and representations specified by competent authorities and respecting the data point definition of the data point model and the validation formulae specified in Annex V as well as the following specifications: (a) information that is not required or not applicable shall not be included in a data submission; (b) numeric values shall be submitted as facts pursuant to the following conventions: (i) data points with the data type Monetary shall be reported using a minimum precision equivalent to thousands of units;

(ii) data points with the data type Percentage shall be expressed as per unit with a minimum precision equivalent to four decimals; (iii) data points with the data type Integer shall be reported using no decimals and a precision equivalent to units. 2. Investment firms shall be identified by their Legal Entity Identifier (LEI). Legal entities and counterparties other than investment firms shall be identified by their LEI, where available. 3. Information submitted by investment firms on the basis of this Regulation shall be accompanied with the following information: (a) reporting reference date and reference period; (b) reporting currency; (c) accounting standard; (d) Legal Entity Identifier (LEI) of the reporting institution; (e) scope of consolidation. CHAPTER II PUBLIC DISCLOSURE BY INVESTMENT FIRMS

Article 9

Disclosure principles

1. Information to be disclosed in accordance with this Regulation shall be subject to the following principles: (a) disclosures shall be subject to the same level of internal verification as that applicable to the management report included in the investment firm’s financial report; (b) disclosures shall be clear and shall be presented in a form that is understandable to users of information and communicated through an accessible medium. Important messages shall be highlighted and easy to find. Complex issues shall be explained in simple language. Related information shall be presented together; (c) disclosures shall be meaningful and consistent over time to enable users of information to compare information across disclosure periods; (d) quantitative disclosures shall be accompanied by qualitative explanations and any other supplementary information that may be necessary in order for the users of that information to understand them, noting in particular any significant change in any given disclosure compared to the information contained in previous disclosures.

Article 10

Disclosure of own funds by investment firms Investment firms shall make the disclosures on own funds required by Article 49(1) of Regulation (EU) 2019/2033 by using the templates of Annex VI to this Regulation and in accordance with the relevant instructions set out in Annex VII to this Regulation.

Article 11

General disclosure provisions

1. Where disclosing the information referred to in Article 10 of this Regulation, investment firms shall ensure that numeric values are submitted as facts in accordance with the following: (a) quantitative monetary data shall be disclosed using a minimum precision equivalent to thousands of units; (b) quantitative data disclosed as Percentage shall be expressed as per unit with a minimum precision equivalent to four decimals.
2. When disclosing the information referred to in Article 10of this Regulation, investment firms shall ensure that the data are associated with all of the following information: (a) disclosure reference date and reference period; (b) disclosure currency; (c) name and where relevant, the Legal Entity Identifier (LEI) of the disclosing institution;

(d) where relevant, the accounting standard; (e) where relevant, the scope of consolidation. CHAPTER III FINAL PROVISIONS

Article 12

Entry into force This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. This Regulation shall be binding in its entirety and directly applicable in all Member States. Done at Brussels, 10 December 2021. For the Commission The President Ursula von der Leyen

Annex

ANNEX I REPORTING FOR INVESTMENT FIRMS OTHER THAN SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS INVESTMENT FIRMS TEMPLATESTemplate numberTemplate codeName of the template /group of templatesShort nameOWN FUNDS: level, composition, requirements and calculation1I 01.00Own fundsI12,1I 02.01Own funds requirementsI2.12,2I 02.02Capital ratiosI2.23I 03.00Fixed overheads requirements calculationI34I 04.00Total K-Factor requirement calculationsI4SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS5I 05.00Level of activity - Thresholds reviewI5K-FACTOR REQUIREMENTS - ADDITIONAL DETAILS6,1I 06.01Assets under management - AUM additional detailI6.16,2I 06.02Average value of total monthly AUMI6.26,3I 06.03Client money held - CMH additional detailI6.36,4I 06.04Average value of total daily CMHI6.46,5I 06.05Assets safeguarded and administered - ASA additional detailI6.56,6I 06.06Average value of total daily ASAI6.66,7I 06.07Client orders handled - COH additional detailI6.76,8I 06.08Average value of total daily COHI6.86,9I 06.09K-Net position risk - K-NPR additional detailI6.96,1I 06.10Clearing Margin given - CMG additional detailI6.106,11I 06.11Trading counterparty default - TCD additional detailI6.116,12I 06.12Daily trading flow - DTF additional detailI6.126,13I 06.13Average value of total daily DTFI6.13CONCENTRATION RISK7I 07.00K-CON - additional detailI78,1I 08.01Level of concentration risk - Client money heldI8.18,2I 08.02Level of concentration risk - Assets seafeguarded and administeredI8.28,3I 08.03Level of concentration risk -Total own cash depositedI8.38,4I 08.04Level of concentration risk - Total earningsI8.48,5I 08.05Trading book exposuresI8.58,6I 08.06Non-trading book and off-balance sheet itemsI8.6LIQUIDITY REQUIREMENTS9I 09.00Liquidity requirementsI9 I 01.00 - OWN FUNDS COMPOSITION (I1) RowsItemAmount00100010OWN FUNDS0020TIER 1 CAPITAL0030COMMON EQUITY TIER 1 CAPITAL0040Fully paid up capital instruments0050Share premium0060Retained earnings0070Previous years retained earnings0080Profit eligible0090Accumulated other comprehensive income0100Other reserves0110Minority interest given recognition in CET1 capital0120Adjustments to CET1 due to prudential filters0130Other funds0140(-)TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 10150(-) Own CET1 instruments0160(-) Direct holdings of CET1 instruments0170(-) Indirect holdings of CET1 instruments0180(-) Synthetic holdings of CET1 instruments0190(-) Losses for the current financial year0200(-) Goodwill0210(-) Other intangible assets0220(-) Deferred tax assets that rely on future profitability and do not arise from temporary differences net of associated tax liabilities0230(-) Qualifying holding outside the financial sector which exceeds 15% of own funds0240(-) Total qualifying holdings in undertaking other than financial sector entities which exceeds 60% of its own funds0250(-) CET1 instruments of financial sector entites where the investment firm does not have a significant investment0260(-) CET1 instruments of financial sector entities where the investment firm has a significant investment0270(-) Defined benefit pension fund assets0280(-) Other deductions0290CET1: Other capital elements, deductions and adjustments0300ADDITIONAL TIER 1 CAPITAL0310Fully paid up, directly issued capital instruments0320Share premium0330(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 10340(-) Own AT1 instruments0350(-) Direct holdings of AT1 instruments0360(-) Indirect holdings of AT1 instruments0370(-) Synthetic holdings of AT1 instruments0380(-) AT1 instruments of financial sector entities where the investment firm does not have a significant investment0390(-) AT1 instruments of financial sector entities where the investment firm has a significant investment0400(-) Other deductions0410Additional Tier 1: Other capital elements, deductions and adjustments0420TIER 2 CAPITAL0430Fully paid up, directly issued capital instruments0440Share premium0450(-) TOTAL DEDUCTIONS FROM TIER 20460(-) Own T2 instruments0470(-) Direct holdings of T2 instruments0480(-) Indirect holdings of T2 instruments0490(-) Synthetic holdings of T2 instruments0500(-) T2 instruments of financial sector entities where the investment firm does not have a significant investment0510(-) T2 instruments of financial sector entities where the investment firm has a significant investment0520Tier 2: Other capital elements, deductions and adjustments

I 02.01 - OWN FUNDS REQUIREMENTS (I2.1) RowsItemAmount00100010Own Funds requirement0020Permanent minimum capital requirement0030Fixed overhead requirement0040Total K-Factor RequirementTransitional own funds requirements0050Transitional requirement based on CRR own funds requirements0060Transitional requirement based on fixed overhead requirements0070Transitional requirement for investment firms previously subject only to an initial capital requirement0080Transitional requirement based on initial capital requirement at authorisation0090Transitional requirement for investment firms that are not authorised to provide certain services0100Transitional requirement of at least 250000 EURMemorandum items0110Additional own funds requirement0120Additional own funds guidance0130Total own funds requirement IF 02.02 - CAPITAL RATIOS (IF2.2) RowsItemAmount00100010CET 1 Ratio0020Surplus(+)/Deficit(-) of CET 1 Capital0030Tier 1 Ratio0040Surplus(+)/Deficit(-) of Tier 1 Capital0050Own Funds Ratio0060Surplus(+)/Deficit(-) of Total capital I 03.00 - FIXED OVERHEADS REQUIREMENT CALCULATION (I3) AmountRowsItem00100010Fixed Overhead Requirement0020Annual Fixed Overheads of the previous year after distribution of profits0030Total expenses of the previous year after distribution of profits0040Of which: Fixed expenses incurred on behalf of the investment firms by third parties0050(-)Total deductions0060(-)Staff bonuses and other remuneration0070(-)Employees', directors' and partners' shares in net profits0080(-)Other discretionary payments of profits and variable remuneration0090(-)Shared commission and fees payable0100(-)Fees, brokerage and other charges paid to CCPs that are charged to customers0110(-)Fees to tied agents0120(-)Interest paid to customers on client money where this is at the firm's discretion0130(-)Non-recurring expenses from non-ordinary activities0140(-)Expenditures from taxes0150(-)Losses from trading on own account in financial instruments0160(-)Contract based profit and loss transfer agreements0170(-)Expenditure on raw materials0180(-)Payments into a fund for general banking risk0190(-)Expenses related to items that have already been deducted from own funds0200Projected fixed overheads of the current year0210Variation of fixed overheads (%) I 04.00 - TOTAL K-FACTOR REQUIREMENT CALCULATIONS (I4) Factor amountK-factor requirementRowsItem001000200010TOTAL K-FACTOR REQUIREMENT0020Risk to client0030Assets under management0040Client money held - Segregated0050Client money held - Non - segregated0060Assets safeguarded and administered0070Client orders handled - Cash trades0080Client orders handled - Derivatives Trades0090Risk to market0100K-Net positions risk requirement0110Clearing margin given0120Risk to firm0130Trading counterparty default0140Daily trading flow - Cash trades0150Daily trading flow - Derivative trades0160K-Concentration risk requirement I 05.00 - LEVEL OF ACTIVITY - THRESHOLDS REVIEW (I5) AmountRowsItem00100010(Combined) assets under management0020(Combined) client orders handled - Cash trades0030(Combined) client orders handled - Derivatives0040Assets safeguarded and administered0050Client money held0060Daily trading flow - cash trades and derivative trades0070Net position risk0080Clearing margin given0090Trading counterparty default0100(Combined) on - and off-balance sheet total0110Combined total annual gross revenue0120Total annual gross revenue0130(-) Intragroup part of the annual gross revenue0140Of which: revenue from reception and transmission of orders0150Of which: revenue from execution of orders0160Of which: revenue from dealing on own account0170Of which: revenue from portfolio management0180Of which: revenue from investment advice0190Of which: revenue from underwriting of financial instruments/placing on a firm commitment basis0200Of which: revenue from placing without a firm commitment basis0210Of which: revenue from operation of an MTF0220Of which: revenue from operation of an OTF0230Of which: revenue from safekeeping and administration of financial instruments0240Of which: revenue from granting credits or loans to investors0250Of which: revenue from advice to undertakings on capital structure, industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings0260Of which: revenue from foreign exchange services0270Of which: investment research and financial analysis0280Of which: revenue from services related to underwriting0290Of which: investment services and ancillary activities related with the underlying of derivatives

I 06.00 K -Factor - additional details (I 06) I 06.01 Assets under management - AUM additional details Factor amountMonth tMonth t-1Month t-20010002000300010Total AUM (average amounts)0020Of which: AUM - Discretionary portfolio management0030Of which: AUM formally delegated to another entity0040AUM - Ongoing non-discretionary advice I 06.02 Monthly assets under management End-of-month valuesMonth t-3Month t-4Month t-5Month t-6Month t-7Month t-8Month t-9Month t-10Month t-11Month t-12Month t-13Month t-14Month t-15Month t-16001000200030004000500060007000800090010001100120013001400010Total monthly assets under management0020Monthly assets under management - discretionary portfolio management0030of which: assets formally delegated to another entity0040Monthly assets under management - Ongoing non-discretionary advice I 06.03 Client money held - CMH additional details Factor amountMonth tMonth t-1Month t-20010002000300010CMH - Segregated (average amounts)0020CMH - Non-segregated (average amounts) I 06.04 Average value of total daily client money held Monthly averages of total daily client money held valuesMonth t-3Month t-4Month t-5Month t-6Month t-7Month t-8Month t-9Month t-10001000200030004000500060007000800010Total daily client money held - Segregated0020Total daily client money held - Non-segregated I 06.05 Assets safeguarded and administered - ASA additional details Factor amountMonth tMonth t-1Month t-20010002000300010Total ASA (average amounts)0020Of which: Fair value of financial instruments (Level 2)0030Of which: Fair value of financial instruments (Level 3)0040Of which: assets formally delegated to another financial entity0050Of which: assets of another financial entity that has formally delegated to the investment firm I 06.06 Average value of total daily assets safeguarded and administered Monthly averages of total daily ASA valuesMonth t-3Month t-4Month t-5Month t-6Month t-7Month t-8Month t-9Month t-10001000200030004000500060007000800010Assets safeguarded and administered0020Of which: Fair value of financial instruments (Level 2)0030Of which: Fair value of financial instruments (Level 3)0040Of which: assets formally delegated to another financial entity0050Of which: assets of another financial entity that has formally delegated to the investment firm I 06.07 Client orders handled - COH additional details Factor amountMonth tMonth t-1Month t-20010002000300010COH - Cash trades (average amounts)0020Of which: Execution of client orders0030Of which: Reception and transmission of client orders0040COH - Derivative (average amounts)0050Of which: Execution of client orders0060Of which: Reception and transmission of client orders I 06.08 Average value of total daily client orders handled Monthly averages of total daily client orders handled valuesMonth t-3Month t-4Month t-5Month t-6Month t-7001000200030004000500010Total daily client orders handled - Cash value0020Of which: Execution of client orders0030Of which: Reception and transmission of client orders0040Total daily client orders handled - Derivatives0050Of which: Execution of client orders0060Of which: Reception and transmission of client orders

I 06.09 K-Net position risk - K-NPR additional detail K - factor requirement / amount00100010Total standardised approach0020Position risk0030Equity instruments0040Debt instruments0050Of which: securitisations0055Particular approach for position risk in CIUs0060Foreign exchange risk0070Commodities risk0080Internal model approach I 06.10 Clearing Margin given - CMG additional detail Clearing memberContribution to the total margin required on a daily basis on the day ofNameCodeType of codethe highest amount of total marginthe second highest amount of total marginthe third highest amount of total margin001000200030004000500060 I 06.11 Trading counterparty default - TCD additional details K - factor requirementExposure valueReplacement cost (RC)Potential future exposure (PFE)Collateral (C)00100020003000400050Breakdown by method for determining the exposure value0010Application of IFR: K-TCD0020Alternative approaches: Exposure value determined in accordance with CRR0030SA-CCR0040Simplified SA-CCR0050Original exposure method0060Alternative approaches: Full application of CRR framework0070Memorandum item: CVA component0080of which: calculated in accordance with CRR frameworkBreakdown by type of counterparty0090Central governments, central banks and public sector entities0100Credit institutions and investment firms0110Other counterparties I 06.12 Daily trading flow - DTF additional details Factor amountMonth tMonth t-1Month t-20010002000300010Total DTF - cash trades (average amounts)0020Total DTF - derivative trades (average amounts) I 06.13 Average value of total daily trading flows Monthly averages of total daily trading flow valuesMonth t-3Month t-4Month t-5Month t-6Month t-7Month t-8Month t-9Month t-10001000200030004000500060007000800010Daily trading flow - cash trades0020Daily trading flow - derivative trades I 07.00 - K-CON - additional detail (I7) Counterparty IDTrading Book Exposures exceeding the limits set in Article 37(1) of IFRCodeType of codeNameGroup/IndividualCounterparty TypeExposure Value (EV)Exposure Value (as % of Own Funds)Own Funds Requirement of total exposure (OFR)Exposure Value Excess (EVE)Duration of the Excess (in days)K-CON Own Funds Requirement for the Excess (OFRE)00100020003000400050006000700080009001000110 I 08.00 - CONCENTRATION RISK - Article 54 IFR (I8) I 08.01 Level of concentration risk - Client money held InstitutionsTotal CMH at reporting dateCodeType of codeNameGroup/IndividualPercentage of client money held at this institution001000200030004000500060 I 08.02 Level of concentration risk - Assets seafeguarded and administered InstitutionsTotal ASA at reporting dateCodeType of codeNameGroup/IndividualPercentage of client securities deposited at this institution001000200030004000500060 I 08.03 Level of concentration risk -Total own cash deposited InstitutionFirm's own cash deposited - Top 5 exposuresCodeType of codeNameGroup/IndividualAmount of firm's cash deposits at the institutionPercentage of firm's own cash deposits at the institution001000200030004000500060

I 08.04 Level of concentration risk - Total earnings ClientEarnings - Top 5 exposuresCodeType of codeNameGroup/IndividualTotal earnings from this clientInterest and dividend incomeFee and commission and other incomeAmount generated from positions in the trading bookAmount generated from positions in the non-trading bookof which: amount generated from off-balance sheet itemsPercentage of interest and dividend income from this clientAmountPercentage of fee and commission and other income from this client00100020003000400050006000700080009001000110 I 08.05 Trading book exposures CounterpartyTop 5 trading book exposuresCodeType of codeNameGroup/IndividualPercentage of exposure to this counterparty with respect to firm's own funds (trading book positions only)00100020003000400050 I 08.06 Non-trading book and off-balance sheet items CounterpartyTop 5 total exposures (including non-trading book and off-balance sheet items)CodeType of codeNameGroup/IndividualPercentage of exposure with respect to firm's own funds (including off-balance sheet assets and non-trading book items)00100020003000400050 I 09.00 - LIQUIDITY REQUIREMENTS (I9) AmountRowsItem00100010Liquidity Requirement0020Client guarantees0030Total liquid assets0040Unencumbered short term deposits0050Total eligible receivables due within 30 days0060Level 1 assets0070Coins and banknotes0080Withdrawable central bank reserves0090Central bank assets0100Central government assets0110Regional government/local authorities assets0120Public Sector Entity assets0130Recognisable domestic and foreign currency central government and central bank assets0140Credit institution (protected by Member State government, promotional lender) assets0150Multilateral development bank and international organisations assets0160Extremely high quality covered bonds0170Level 2A assets0180Regional government/local authorities or Public Sector Entities assets (Member State, RW20 %)0190Central bank or central/regional government or local authorities or Public Sector Entities assets (Third Country, RW20 %)0200High quality covered bonds (CQS2)0210High quality covered bonds (Third Country, CQS1)0220Corporate debt securities (CQS1)0230Level 2B assets0240Asset-backed securities0250Corporate debt securities0260Shares (major stock index)0270Restricted-use central bank committed liquidity facilities0280High quality covered bonds (RW35 %)0290Qualifying CIU shares/units0300Total other eligible financial instruments

Annex

ANNEX II REPORTING FOR INVESTMENT FIRMS OTHER THAN SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS Table of contents PART I: GENERAL INSTRUCTIONS 68

1. Structure and conventions 68 1.1 Structure 68 1.2 Numbering convention 68 1.3 Sign convention 68 1.4 Prudential consolidation 68 PART II: TEMPLATE RELATED INSTRUCTIONS 69
2. OWN FUNDS: LEVEL, COMPOSITION, REQUIREMENTS AND CALCULATION 69 1.1 General Remarks 69 1.2. I 01.00 – OWN FUNDS COMPOSITION (I 1) 69 1.2.1. Instructions concerning specific positions 69 1.3. I 02.01 – OWN FUND REQUIREMENTS (I 2.1)

76 1.3.1. Instructions concerning specific positions 76 1.4. I 02.02 – CAPITAL RATIOS (I 2.2) 78 1.4.1. Instructions concerning specific positions 78 1.5. I 03.00 – FIXED OVERHEADS REQUIREMENT CALCULATION (I 3) 78 1.5.1. Instructions concerning specific positions 78 1.6. I 04.00 – TOTAL K-FACTOR REQUIREMENT CALCULATIONS (I 4) 81 1.6.1. Instructions concerning specific positions 81 2. SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS 83 2.1. I 05.00 – LEVEL OF ACTIVITY – THRESHOLD REVIEW (I 5) 83 2.1.1 Instructions concerning specific positions 83 3. K-FACTOR REQUIREMENTS – ADDITIONAL DETAILS 86 3.2. I 06.01 – ASSETS UNDER MANAGEMENT – ADDITIONAL DETAILS (I 6.1) 86 3.2.1. Instructions concerning specific positions 80 3.3. I 06.02 – MONTHLY ASSETS UNDER MANAGEMENT (I 6.2) 86 3.3.1. Instructions concerning specific positions 87 3.4. I 06.03 – CLIENT MONEY HELD- ADDITIONAL DETAIL (I 6.3) 87 3.4.1. Instructions concerning specific positions 88 3.5. I 06.04 – AVERAGE VALUE OF TOTAL DAILY CLIENT MONEY HELD (I 6.4) 89 3.5.1. Instructions concerning specific positions 89 3.6. I 06.05 – ASSETS SAFEGUARDED AND ADMINISTERED – ADDITIONAL DETAIL (I 6.5) 89 3.6.1. Instructions concerning specific positions 89 3.7. I 06.06 – AVERAGE VALUE OF TOTAL DAILY ASSETS SAFEGUARDED AND ADMINISTERED (I 6.6) 90 3.7.1. Instructions concerning specific positions 90 3.8. I 06.07 – CLIENT ORDERS HANDLED – ADDITIONAL DETAILS (I 6.7) 91 3.8.1. Instructions concerning specific positions 91 3.9. I 06.08 – AVERAGE VALUE OF TOTAL DAILY CLIENT ORDERS HANDLED (I 6.8) 93 3.9.1. Instructions concerning specific positions 91 3.10. I 06.09 – K-NET POSITION RISK – ADDITIONAL DETAILS (I 6.9) 93 3.10.1. Instructions concerning specific positions 93 3.11. I 06.10 – CLEARING MARGIN GIVEN – ADDITIONAL DETAIL (I 6.10) 94 3.11.1 Instructions concerning specific positions 94 3.12. I 06.11 – TRADING COUNTERPARTY DEFAULT- TCD ADDITIONAL DETAILS (I 6.11) 95 3.12.1. Instructions concerning specific positions 95 3.13. I 06.12– DAILY TRADING FLOW- ADDITIONAL DETAILS (I 6.12) 96 3.13.1. Instructions concerning specific positions 96 3.14. I 06.13– AVERAGE VALUE OF TOTAL DAILY TRADING FLOWS (I 6.13) 98 3.14.1. Instructions concerning specific positions 98 4. CONCENTRATION RISK REPORTING 98 4.1. General Remarks 98 4.2. I 07.00 – K-CON ADDITIONAL DETAILS (I7) 99 4.2.1. Instructions concerning specific positions 99 4.3. I 08.01 – LEVEL OF CONCENTRATION RISK – CLIENT MONEY HELD (I 8.1) 99 4.3.1. Instructions concerning specific columns 99 4.4. I 08.02 – LEVEL OF CONCENTRATION RISK – ASSETS SAFEGUARDED AND ADMINISTERED (I 8.2) 101 4.4.1. Instructions concerning specific columns 101 4.5. I 08.03 – LEVEL OF CONCENTRATION RISK -TOTAL OWN CASH DEPOSITED (I 8.3) 101 4.5.1. Instructions concerning specific columns 101 4.6. I 08.04 – LEVEL OF CONCENTRATION RISK – TOTAL EARNINGS (I 8.4) 102 4.6.1. Instructions concerning specific columns 102 4.7. I 08.05 – TRADING BOOK EXPOSURES (I 8.5) 103 4.7.1. Instructions concerning specific columns

103 4.8. I 08.06 – NON-TRADING BOOK AND OFF-BALANCE SHEET ITEMS (I 8.6) 104 4.8.1. Instructions concerning specific columns 104 5. LIQUIDITY REQUIREMENTS 105 5.1 I 09.00 – LIQUIDITY REQUIREMENTS (I 9) 105 5.1.1. Instructions concerning specific positions 106 PART I: GENERAL INSTRUCTIONS

1. Structure and conventions 1.1 Structure
2. Overall, the framework consists of the following blocks of information: (a) Own funds; (b) Own funds requirements calculations; (c) Fixed overheads requirements calculation; (d) Level of activity in respect of the conditions set out in Article 12(1) of Regulation (EU) 2019/2033; (e) K-factor requirements calculations; (f) Concentration risk requirements; (g) Liquidity requirements.
3. For each template legal references are provided. Further detailed information regarding more general aspects of the reporting of each block of templates, instructions concerning specific positions as well as validation rules are included in this part of this Regulation. 1.2 Numbering convention
4. The document follows the labelling convention set in points 4 to 7, when referring to the columns, rows and cells of the templates. Those numerical codes are extensively used in the validation rules.
5. The following general notation is followed in the instructions: {Template; Row; Column}.
6. In the case of validations inside a template, in which only data points of that template are used, notations do not refer to a template: {Row; Column}.
7. In the case of templates with only one column, only rows are referred to. {Template; Row}
8. An asterisk sign is used to express that the validation is done for the rows or columns specified before. 1.3 Sign convention
9. Any amount that increases the own funds or own funds requirements, or the liquidity requirements, shall be reported as a positive figure. On the contrary, any amount that reduces the total own funds or own funds requirements shall be reported as a negative figure. Where there is a negative sign (-) preceding the label of an item no positive figure is expected to be reported of that item. 1.4 Prudential consolidation
10. Unless an exemption has been granted, Regulation (EU) 2019/2033 and Directive (EU) 2019/2034 apply to investment firms on an individual and on a consolidated basis, which includes reporting requirements in Part Seven of Regulation (EU) 2019/2033. Article 4(1), point (11), of Regulation (EU) 2019/2033 defines a consolidated situation as the result of applying the requirements of Regulation (EU) 2019/2033 to an investment firm group as if the entities of the group formed together a single investment firm. Following the application of Article 7 of Regulation (EU) 2019/2033, investment firms groups shall fulfil the reporting requirements in all templates based on their scope of prudential consolidation (which may be different from their accounting consolidation scope). PART II: TEMPLATE RELATED INSTRUCTIONS
11. OWN FUNDS: LEVEL, COMPOSITION, REQUIREMENTS AND CALCULATION 1.1 General Remarks

1. The own funds’ overview section contains information about the own funds that an investment firm holds and its own funds requirements. It consists of two templates: (a) I 01.00 template contains the compositions of the own funds that an investment firm holds: Common Equity Tier 1 capital (CET1), Additional Tier 1 capital (AT1) and Tier 2 capital (T2). (b) I 02.01 and I 02.02 templates contain the total own funds requirement, the permanent minimum capital requirement, the fixed overheads requirement and total K-Factor requirement, any additional own funds requirement and guidance and the transitional own funds requirement and capital ratios. (c) I 03.00 includes information with regard to the calculation of the fixed overheads requirement. (d) I 04.00 template contains the K-factors requirements and the factor amount.
2. The items in these templates are gross of transitional adjustments. This means that the figures (except where the transitional own funds requirement is specifically stated) are calculated in accordance with the final provisions (i.e. as if there were no transitional provisions). 1.2. I 01.00 – OWN FUNDS COMPOSITION (I 1) 1.2.1. Instructions concerning specific positions RowLegal references and instructions0010 OWN FUNDS

Article 36(1), point (e), of Regulation (EU) No 575/2013. 0280 (-) Other deductions The sum of all other deductions in accordance with Article 36(1) of Regulation (EU) No 575/2013 that are not included in any of the rows 0150 to 0270 above. 0290 CET1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered CET1 Capital instruments (Article 483, paragraphs 1, 2 and 3 and Articles 484 to 487 of Regulation (EU) No 575/2013). Transitional adjustments due to additional minority interests (Articles 479 and 480 of Regulation (EU) No 575/2013). Other transitional adjustments to CET1 Capital (Articles 469 to 478 and 481 of Regulation (EU) No 575/2013): adjustments to the deductions from CET1 due to transitional provisions Other CET1 capital elements or deductions from a CET1 element that cannot be assigned to one of the rows 0040 to 0280. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios 0300 ADDITIONAL TIER 1 CAPITAL

Article 56, point (d), of Regulation (EU) No 575/2013. 0400 (-) Other deductions The sum of all other deductions in accordance with Article 56 of Regulation (EU) No 575/2013 that are not included in any of the rows 0340 to 0390 above. 0410 Additional Tier 1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered AT1 capital instruments (Article 483, paragraphs 4 and 5, Articles 484 to 487, Articles 489 and 491 of Regulation (EU) No 575/2013). Instruments issued by subsidiaries that are given recognition in AT1 capital (Articles 83, 85 and 86 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying Tier 1 capital of subsidiaries that is included in consolidated AT1, also including capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013). Transitional adjustments due to additional recognition in AT1 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013) adjustments to the qualifying Tier 1 capital included in consolidated AT1 capital due to transitional provisions. Other transitional adjustments to AT1 Capital (Articles 472, 473a, 474, 475, 478 and 481 of Regulation (EU) No 575/2013): adjustments to deductions due to transitional provisions. Excess of deduction from AT1 items over AT1 Capital, deducted from CET1 in accordance with Article 36(1), point (j), of Regulation (EU) No 575/2013: Additional Tier 1 cannot be negative, but it is possible that the deductions from AT1 items exceed the amount of available AT1 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0300 to zero and equals the inverse of the excess of deductions from AT1 items over AT1 capital included, among other deductions, in row 0280. Other AT1 capital elements or deductions from an AT1 element that cannot be assigned to one of the rows 0310 to 0400. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios. 0420 TIER 2 CAPITAL

Article 4(1), point (27), Article 66, point (d), and Articles 68, 69 and 79 of Regulation (EU) No 575/2013. Holdings by the institution of T2 instruments of financial sector entities (as defined in Article 4(1), point (27), of Regulation (EU) No 575/2013 where the investment firm has a significant investment shall be completely deducted. 0520 Tier 2: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered T2 capital instruments (Article 483, paragraphs 6 and 7, Articles 484, 486, 488, 490 and 491 of Regulation (EU) No 575/2013). Instruments issued by subsidiaries that are given recognition in T2 capital (Articles 83, 87 and 88 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying own funds of subsidiaries that is included in consolidated T2, also including qualifying Tier 2 capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013). Transitional adjustments due to additional recognition in T2 capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013): Adjustments to the qualifying own funds included in consolidated T2 capital due to transitional provisions. Other transitional adjustments to T2 Capital (Articles 472, 473a, 476, 477, 478 and 481 of Regulation (EU) No 575/2013): Adjustments to the deductions from Tier 2 due to transitional provisions. Excess of deduction from T2 items over T2 capital, deducted from AT1 in accordance with Article 56 of Regulation (EU) No 575/2013, point (e): Tier 2 cannot be negative, but it is possible that the deductions from T2 items exceed the amount of available T2 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0420 to zero. Other T2 capital elements or deductions from a T2 element that cannot be assigned to one of the rows 0430 to 0510. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios. 1.3. I 02.01 – OWN FUND REQUIREMENTS (I 2.1) 1.3.1. Instructions concerning specific positions RowLegal references and instructions0010 Own fund requirement

Article 41 of Directive (EU) 2019/2034. Additional own funds required as additional own funds guidance. 0130 Total own funds requirement The total own funds requirement of an investment firm shall consist of the sum of its own funds requirements applicable at the reference date, the additional own funds requirement as reported in row 0110 and the additional own funds guidance as reported in row 0120. 1.4. I 02.02 – CAPITAL RATIOS (I 2.2) 1.4.1. Instructions concerning specific positions RowLegal references and instructions0010 CET 1 Ratio

Article 9(1), point (c), and Article 11(1) of Regulation (EU) 2019/2033. This item is expressed as a percentage. 0060 Surplus(+)/Deficit(-) of Total capital This item shows the surplus or deficit of own funds relating to the requirement set in Article 9(1) of Regulation (EU) 2019/2033. The transitional provisions of Article 57(3) and (4) of Regulation (EU) 2019/2033 shall not be considered for this item. 1.5. I 03.00 – FIXED OVERHEADS REQUIREMENT CALCULATION (I 3) 1.5.1. Instructions concerning specific positions RowLegal references and instructions0010 Fixed Overhead Requirement

Article 13(1) of Regulation (EU) 2019/2033. The amount reported shall be at least 25 % of the annual fixed overheads of the previous year (row 0020). In the cases where there is a material change, the amount reported shall be the fixed overheads requirement imposed by the competent authority in accordance with Article 13(2) of Regulation (EU) 2019/2033. In the cases specified in Article 13(3) of Regulation (EU) 2019/2033, the amount to be reported shall be the projected fixed overheads of the current year (row 0210). 0020 Annual fixed overheads of the previous year after distribution of profits

Article 13(1) of Regulation (EU) 2019/2033. The amount to be reported shall be after the distribution of profits. 0040 Of which: Fixed expenses incurred on behalf of the investment firms by third parties Where third parties, including tied agents, incurred fixed expenses, on behalf of the investment firms, that are not already included within the total expenses in the annual financial statement referred to in paragraph 1, those fixed expenses shall be added to the total expenses of the investment firm. Where a breakdown of the third party’s expenses is available, an investment firm shall add to the figure representing the total expenses only the share of those fixed expenses applicable to the investment firm. Where such a breakdown is not available, an investment firm shall add to the figure representing the total expenses only its share of the third party’s expenses as it results from the business plan of the investment firm. 0050 (-)Total deductions In addition to the items for deduction referred to in Article 13(4) of Regulation (EU) 2019/2033, the following items shall also be deducted from the total expenses, where they are included under total expenses in accordance with the relevant accounting framework: (a) fees, brokerage and other charges paid to central counterparties, exchanges and other trading venues and intermediate brokers for the purposes of executing, registering or clearing transactions, only where they are directly passed on and charged to customers. Those shall not include fees and other charges necessary to maintain membership or otherwise meet loss-sharing financial obligations to central counterparties, exchanges and other trading venues; (b) interest paid to customers on client money, where there is no obligation of any kind to pay such interest; (c) expenditures from taxes where they fall due in relation to the annual profits of the investment firm; (d) losses from trading on own account in financial instruments; (e) payments related to contract-based profit and loss transfer agreements according to which the investment firm is obliged to transfer, following the preparation of its annual financial statements, its annual result to the parent undertaking; (f) payments into a fund for general banking risk in accordance with Article 26(1)(f) of Regulation (EU) No 575/2013; (g) expenses related to items that have already been deducted from own funds in accordance with Article 36(1) of Regulation (EU) No 575/2013. 0060 (-)Staff bonuses and other remuneration

Article 13(4), point (a), of Regulation (EU) 2019/2033. Staff bonuses and other remuneration shall be considered to depend on the net profit of the investment firm in the respective year where both of the following conditions are met: (h) the staff bonuses or other remuneration to be deducted have already been paid to employees in the year preceding the year of payment, or the payment of the staff bonuses or other remuneration to employees will have no impact on the firm’s capital position in the year of payment; (i) with respect to the current year and future years, the firm is not obliged to award or allocate further bonuses or other payments in the form of remuneration unless it makes a net profit in that year. 0070 (-)Employees’, directors’ and partners’ shares in net profits

Article 13(4), point (d), of Regulation (EU) 2019/2033. 0100 (-)Fees, brokerage and other charges paid to CCPs that are charged to customers Fees, brokerage and other charges paid to central counterparties, exchanges and other trading venues and intermediate brokers for the purposes of executing, registering or clearing transactions, only where they are directly passed on and charged to customers. Those shall not include fees and other charges necessary to maintain membership or otherwise meet loss-sharing financial obligations to central counterparties, exchanges and other trading venues; 0110 (-)Fees to tied agents

Article 13(4), point (f), of Regulation (EU) 2019/2033. 0140 (-)Expenditures from taxes Expenditures from taxes where they fall due in relation to the annual profits of the investment firm. 0150 (-)Losses from trading on own account in financial instruments Losses due to trading on own account in financial instruments. 0160 (-)Contract based profit and loss transfer agreements Payments related to contract-based profit and loss transfer agreements according to which the investment firm is obliged to transfer, following the preparation of its annual financial statements, its annual result to the parent undertaking. 0170 (-)Expenditure on raw materials Commodity and emission allowance dealers may deduct expenditure on raw materials in connection with an investment firm trading in derivatives of the underlying commodity. 0180 (-)Payments into a fund for general banking risk payments into a fund for general banking risk in accordance with Article 26(1)(f), of Regulation (EU) No 575/2013. 0190 (-)Expenses related to items that have already been deducted from own funds Expenses related to items that have already been deducted from own funds in accordance with Article 36(1) of Regulation (EU) No 575/2013 0200 Projected fixed overheads of the current year The projection of the fixed overheads for the current year after the distribution of profits. 0210 Variation of fixed overheads (%) The amount shall be reported as the absolute value of: [(Projected fixed overheads of the current year) – (Annual fixed overheads of the previous year)]/(Annual fixed overheads of the previous year). 1.6. I 04.00 – TOTAL K-FACTOR REQUIREMENT CALCULATIONS (I 4) 1.6.1. Instructions concerning specific positions RowLegal references and instructions0010 TOTAL K-FACTOR REQUIREMENT

Article 26 and Article 24 of Regulation (EU) 2019/2033. 0140 Daily trading flow – Cash trades For the purposes of K-factor requirement calculation, investment firms shall report by applying the coefficient of Article 15(2) of Regulation (EU) 2019/2033. In the event of stressed market conditions, in accordance with Article 15(5), point (c), of Regulation (EU) 2019/2033, investment firms shall apply an adjusted coefficient as specified in Article 1(1), point (a), of the RTS to specify adjustments to the K-DTF coefficients. The daily trading flow factor shall be calculated in accordance with Article 33(2), point (a), of Regulation (EU) 2019/2033. 0150 Daily trading flow – Derivative trades For the purposes of the K-factor requirement calculation, investment firms shall report by applying the coefficient of Article 15(2) of Regulation (EU) 2019/2033. In the event of stressed market conditions, in accordance with Article 15(5), point (c), of Regulation (EU) 2019/2033, investment firms shall apply an adjusted coefficient as specified in Article 1(1), point (b), of the RTS to specify adjustments to the K-DTF coefficients. The daily trading flow factor shall be calculated in accordance with Article 33(2), point (b) of Regulation (EU) 2019/2033. 0160 K-Concentration risk requirement

Article 37(2), Article 39 and Article 24 of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010 Factor amount Investment firms shall report the amount, which corresponds to each of the factors, before multiplying each factor by the corresponding coefficient. 0020 K-Factor requirement Shall be calculated in accordance with Article 16, 21 and 24 of Regulation (EU) 2019/2033. 2. SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS 2.1 I 05.00 – LEVEL OF ACTIVITY – THRESHOLD REVIEW (I 5) 2.1.1. Instructions concerning specific positions RowLegal references and instructions0010 (Combined) assets under management

Article 12(1), point (a), of Regulation (EU) 2019/2033. Where the reporting investment firm is part of a group, the value reported shall be determined on a combined basis for all investment firms that are part of a group pursuant to Article 12(2) of Regulation (EU) 2019/2033. Investment firms shall include discretionary and non-discretionary assets under management. The amount reported shall be the amount that would be used for calculation of K-factors before application of relevant coefficients. 0020 (Combined) client orders handled – Cash trades

Article 12(1), point (i), of Regulation (EU) 2019/2033. Where the reporting investment firm is part of a group, the value reported shall be determined on a combined basis for all investment firms that are part of a group pursuant to Article 12(2) of Regulation (EU) 2019/2033. 0120 Total annual gross revenue The value of total annual gross revenue excluding the gross revenues generated within the group pursuant to Article 12(2) of Regulation (EU) 2019/2033. 0130 (-) Intragroup part of the annual gross revenue The value of the gross revenues generated within the investment firm group pursuant to Article 12(2) of Regulation (EU) 2019/2033. 0140 Of which: revenue from reception and transmission of orders

Article 4(1), point (3), of Directive 2014/65/EU. 3. K-FACTOR REQUIREMENTS – ADDITIONAL DETAILS 3.1. General remarks 12. In I 06.00 each of the K-factors AUM, ASA, CMH, COH and DTF have two designated tables. 13. The first table contains in columns information related to Factor amount for each month of the reporting quarter. Factor amount is the value that is used for the calculation of each K-factor before applying the coefficient from Table 1 of Article 15(2) of Regulation (EU) 2019/2033. 14. The second table contains detailed information necessary to calculate the Factor amount. In case of AUM, this corresponds to the value of assets under management as of the last day of the month as specified in Article 17 of Regulation (EU) 2019/2033. In the case of CMH, ASA, COH and DTF, the value reported shall correspond to the average of the daily value of the relevant indicator over the month. 3.2. I 06.01 – ASSETS UNDER MANAGEMENT – ADDITIONAL DETAILS (I 6.1) 3.2.1. Instructions concerning specific positions RowLegal references and instructions0010 Total AUM (average amounts)

Article 4(1), point (27), of Regulation (EU) 2019/2033. Total AUM value as an arithmetic mean in accordance with Article 17(1), first subparagraph, of Regulation (EU) 2019/2033. The value reported shall be the sum of rows 0020 and 0040. 0020 Of which: AUM – Discretionary portfolio management Total amount of assets in relation to which the investment firm performs the service of portfolio management as defined in Article 4(1), point (8), of Directive 2014/65/EU and calculated in accordance with Article 17(1) of Regulation (EU) 2019/2033. 0030 Of which: AUM formally delegated to another entity

Article 17(2) of Regulation (EU) 2019/2033. 0040 AUM – Ongoing non-discretionary advice Total amount of assets in relation to which the investment firm performs the service of investment advice as defined in Article 4(1), point (4), of Directive 2014/65/EU on an ongoing and non-discretionary basis. ColumnsLegal references and instructions0010 Factor amount – Month t AUM for the end of the third month (i.e. the most recent) of the quarter the report refers to. 0020 Factor amount – Month t-1 AUM for the second month of the quarter the report refers to. 0030 Factor amount – Month t-2 AUM for the first month of the quarter the report refers to. 3.3. I 06.02 – MONTHLY ASSETS UNDER MANAGEMENT (I 6.2) 3.3.1. Instructions concerning specific positions RowLegal references and instructions0010 Total monthly assets under management

Article 4(1), point (27), of Regulation (EU) 2019/2033. The total monthly assets under management as of the last business day of the relevant month as referred to in Article 17(1) of Regulation (EU) 2019/2033. The amount reported in this row shall be the sum of rows 0020 and 0040. 0020 Monthly assets under management – discretionary portfolio management The amount reported shall be the monthly assets in relation to which the investment firm performs the service of portfolio management as defined in Article 4(1), point (8), of Directive 2014/65/EU as of the last business day of the relevant month as referred to in Article 17(1) of Regulation (EU) 2019/2033. 0030 Of which: assets formally delegated to another entity

Article 17(2) of Regulation (EU) 2019/2033. Monthly assets which management was formally delegated to another entity reported as of the last business day of the relevant month. 0040 Monthly assets under management – Ongoing non-discretionary advice Total amount of assets in relation to which the investment firm performs the service of investment advice as defined in Article 4(1), point (4), of Directive 2014/65/EU on an ongoing and non-discretionary basis reported as of the last business day of the relevant month. ColumnsLegal references and instructions0010-0140 End-of-month values Values as of the last business day of the relevant month as referred to in Article 17(1) of Regulation (EU) 2019/2033 shall be reported. 3.4. I 06.03 – CLIENT MONEY HELD- ADDITIONAL DETAIL (I 6.3) 3.4.1. Instructions concerning specific positions RowLegal references and instructions0010 CMH – Segregated (average amounts)

Article 4(1), points (28) and (49), of Regulation (EU) 2019/2033. The value reported shall be the arithmetic mean of the daily values of CMH where client money is not held in segregated accounts in accordance with Article 18(1), first subparagraph of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010 Factor amount – Month t CMH for the end of the third month (i.e. the most recent) of the quarter the report refers to. This amount is calculated as the arithmetic mean of daily amounts within the time period specified in Article 18(1) of Regulation (EU) 2019/2033. 0020 Factor amount – Month t-1 CMH for the end of the second month of the quarter the report refers to. This amount is calculated as the arithmetic mean of daily amounts within the time period specified in Article 18(1) of Regulation (EU) 2019/2033. 0030 Factor amount – Month t-2 CMH for the end of the first month of the quarter the report refers to. This amount is calculated as the arithmetic mean of daily amounts within the time period specified in Article 18(1) of Regulation (EU) 2019/2033. 3.5. I 06.04 – AVERAGE VALUE OF TOTAL DAILY CLIENT MONEY HELD (I 6.4) 3.5.1. Instructions concerning specific positions RowLegal references and instructions0010 Total daily client money held – Segregated

Article 4(1), points (28) and (49), of Regulation (EU) 2019/2033 The value reported shall be the monthly average of the total daily client money held where client money is not held in segregated accounts in accordance with Article 18(1) of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010-0080 Monthly averages of total daily client money held values Investment firms shall report in each month, the monthly average value of total daily client money held measured at the end of each business day as per Article 18(1) of Regulation (EU) 2019/2033. 3.6. I 06.05 – ASSETS SAFEGUARDED AND ADMINISTERED – ADDITIONAL DETAIL (I 6.5) 3.6.1. Instructions concerning specific positions RowLegal references and instructions0010 Total ASA (average amounts)

Article 19(2) of Regulation (EU) 2019/2033. Value of assets of another financial entity that has formally delegated safeguarding and administration to the investment firm as an arithmetic mean in accordance with Article 19(1), first subparagraph of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010 Factor amount – Month t ASA for the end of the third month (i.e. the most recent) of the quarter the report refers to. 0020 Factor amount – Month t-1 ASA for the end of the second month of the quarter the report refers to. 0030 Factor amount – Month t-2 ASA for the end of the first month of the quarter the report refers to. 3.7. I 06.06 – AVERAGE VALUE OF TOTAL DAILY ASSETS SAFEGUARDED AND ADMINISTERED (I 6.6) 3.7.1. Instructions concerning specific positions RowLegal references and instructions0010 Assets safeguarded and administered

Article 19(2) of Regulation (EU) 2019/2033. The value reported shall be the monthly average of the total daily assets of another financial entity that has formally delegated safeguarding and administration to the investment firm in accordance with Article 19(1) of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010-0080 Monthly averages of total daily assets safeguarded and administered values Investment firms shall report in each month, the daily average value of total daily assets safeguarded and administered measured at the end of each business day as per Article 19(1) of Regulation (EU) 2019/2033. 3.8. I 06.07 – CLIENT ORDERS HANDLED – ADDITIONAL DETAILS (I 6.7) 3.8.1. Instructions concerning specific positions RowLegal references and instructions0010 COH – Cash trades (average amounts) Value of COH – cash trades as defined in Article 4(1), point (30), of Regulation (EU) 2019/2033 and measured pursuant to Article 20(1) of Regulation (EU) 2019/2033. Investment firms shall report the arithmetic mean amount of COH – cash trades for the previous six months, excluding the three most recent months according with Article 20(1), first subparagraph of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 20(2), point (a), of Regulation (EU) 2019/2033. 0020 Of which: Execution of client orders COH for cash trades in relation to which the investment firm perform the service of execution of client orders in client’s name as defined in Article 4(1), point (5), of Directive 2014/65/EU. The arithmetic mean amount of COH value for the previous six months, excluding the three most recent months according with Article 20(1), first subparagraph of Regulation (EU) 2019/2033 shall be reported. 0030 Of which: Reception and transmission of client orders COH for cash trades in relation to which the investment firm perform the service of reception and transmission of client orders. The arithmetic mean amount of COH value for the previous six months, excluding the three most recent months according with Article 20(1), first subparagraph of Regulation (EU) 2019/2033 shall be reported. 0040 COH – Derivatives (average amounts)

Article 4(1), point (30), of Regulation (EU) 2019/2033. Investment firms shall report the arithmetic mean amount of COH – derivatives for the previous six months, excluding the three most recent months according with Article 20(1), first subparagraph of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 20(2), point (b), of Regulation (EU) 2019/2033. 0050 Of which: Execution of client orders COH for derivative trades in relation to which the investment firm perform the service of execution of client orders in client’s name as defined in Article 4(1), point (5), of Directive 2014/65/EU. The arithmetic mean amount of COH value for the previous six months, excluding the three most recent months, pursuant to Article 20(1), first subparagraph of Regulation (EU) 2019/2033 shall be reported. 0060 Of which: Reception and transmission of client orders COH for derivative trades in relation to which the investment firm perform the service of reception and transmission of client orders. The arithmetic mean amount of COH value for the previous six months, excluding the three most recent months pursuant to Article 20(1), first subparagraph, of Regulation (EU) 2019/2033 shall be reported. ColumnsLegal references and instructions0010 Factor amount – Month t Value of COH as of the end of the third month (i.e. the most recent) of the quarter the report refers to. 0020 Factor amount – Month t-1 Value of COH as of the end of the second month of the quarter the report refers to. 0030 Factor amount – Month t-2 Value of COH as of the end of the first month of the quarter the report refers to. 3.9. I 06.08 – AVERAGE VALUE OF TOTAL DAILY CLIENT ORDERS HANDLED (I 6.8) 3.9.1. Instructions concerning specific positions RowLegal references and instructions0010 Total daily client orders handled – Cash trades

Article 4(1), point (30), of Regulation (EU) 2019/2033. The average value of the total daily client orders handled (cash trades) of the relevant month as referred to in Article 20(1) of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 20(2), point (a), of Regulation (EU) 2019/2033. 0020 Of which: Execution of client orders The average value of the total daily client orders handled for cash trades in relation to which the investment firm perform the service of execution of client orders in client’s name as defined in Article 4(1), point (5), of Directive 2014/65/EU. 0030 Of which: Reception and transmission of client orders The average value of the total daily client orders handled for cash trades in relation to which the investment firm perform the service of reception and transmission of client orders. 0040 Total daily client orders handled – Derivatives

Article 4(1), point (30), of Regulation (EU) 2019/2033. The average value of the total daily client orders handled (derivatives) of the relevant month as referred to in Article 20(1) of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 20(2), point (b), of Regulation (EU) 2019/2033. 0050 Of which: Execution of client orders The average value of the total daily client orders handled for derivative trades in relation to which the investment firm perform the service of execution of client orders in client’s name as defined in Article 4(1), point (5), of Directive 2014/65/EU. 0060 Of which: Reception and transmission of client orders The average value of the total daily client orders handled for derivative trades in relation to which the investment firm perform the service of reception and transmission of client orders. ColumnsLegal references and instructions0010-0050 Monthly averages of total daily client orders handled values Investment firms shall report each month the monthly average value of the total daily client orders handled as per Article 20(1). 3.10. I 06.09 – K-NET POSITION RISK – ADDITIONAL DETAILS (I 6.9) 3.10.1. Instructions concerning specific positions RowLegal references and instructions0010 Total standardised approach

Article 22 (a) and 21(3) of Regulation (EU) 2019/2033. Trading book positions in for which an own funds requirement for position risk is determined in accordance with Chapter 2 of Title IV of Part Three of Regulation (EU) No 575/2013. 0030 Equity instruments Articles 22(a) and 21(3) of Regulation (EU) 2019/2033. Trading book positions in equity instruments for which an own funds requirement is determined in accordance with Section 3 of Chapter 2 of Title IV of Part Three of Regulation (EU) No 575/2013. 0040 Debt instruments Articles 22(a) and 21(3) of Regulation (EU) 2019/2033. Trading book positions in debt instruments for which an own funds requirement is determined in accordance with Section 2 of Chapter 2 of Title IV of Part Three of Regulation (EU) No 575/2013. 0050 Of which: securitisations Articles 22 (a) and 21(3) of Regulation (EU) 2019/2033. Positions in securitisation instruments as referred to in Article 337 of Regulation (EU) No 575/2013 and positions in the correlation trading portfolio as referred to in Article 338 of Regulation (EU) No 575/2013. 0055 Particular approach for position risk in CIUs

Article 22 (a) and 21(3) of Regulation (EU) 2019/2033. Total risk exposure amount for positions in CIUs if capital requirements are calculated in accordance with Article 348(1) of Regulation (EU) No 575/2013 either immediately or as a consequence of the cap defined in Article 350(3), point (c), of Regulation (EU) No 575/2013. Regulation (EU) No 575/2013 does not explicitly assign those positions to either the interest rate risk or the equity risk. If the particular approach in accordance with the first sentence of Article 348(1) of Regulation (EU) No 575/2013 is applied, the amount to be reported is 32 % of the net position of the CIU exposure in question. If the particular approach in accordance with the second sentence of Article 348(1) of Regulation (EU) No 575/2013 is applied, the amount to be reported is the lower of 32 % of the net position of the relevant CIU exposure and the difference between 40 % of this net position and the own funds requirements that arise from the foreign exchange risk associated with this CIU exposure. 0060 Foreign exchange risk

Article 57(2) and Article 21, paragraphs (3) and (4) of Regulation (EU) 2019/2033. Trading book positions and positions in the non-trading book that are subject to foreign exchange or commodities risk for which the own funds requirement is determined in accordance with Chapter 5 of Title IV of Part Three of Regulation (EU) No 575/2013. 3.11. I 06.10 – CLEARING MARGIN GIVEN – ADDITIONAL DETAIL (I 6.10) 15. In this template, firms dealing on own account shall report all clearing members of qualifying central counterparties under whose responsibility the execution and settlement of transactions of the firm takes place. 3.11.1. Instructions concerning specific positions ColumnLegal references and instructions0010 – 0030Clearing member0010 Name Investment firms shall report the name of any clearing member of qualifying central counterparties under whose responsibility the execution and settlement of transactions of the firm dealing on its own account takes place. 0020 Code The code as part of a row identifier must be unique for each reported entity. For investment firms the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0030 Type of code The type of code reported in column 0020 shall be identified as a LEI code type or National code type. 0040 – 0060 Contribution to the total margin required on a daily basis Investment firms shall report information for the three days of the preceding three months where the highest, second highest and third highest amount of total margin required on a daily basis, as referred to in Article 23(2) of Regulation (EU) 2019/2033, was calculated. The investment firm shall include all clearing members in the template that were used on at least one of those days. The contribution to the total margin required on a daily basis shall be reported as the amount before the multiplication with the factor of 1.3 referred to in Article 23(2) of Regulation (EU) 2019/2033. 0040Contribution to the total margin required on a daily basis – on the day of the highest amount of total margin required0050Contribution to the total margin required on a daily basis – on the day of the second highest amount of total margin required0060Contribution to the total margin required on a daily basis – on the day of the third highest amount of total margin required 3.12. I 06.11 – TRADING COUNTERPARTY DEFAULT- TCD ADDITIONAL DETAILS (I 6.11) 3.12.1. Instructions concerning specific positions RowLegal references and instructions0010 – 0080Breakdown by method for determining the exposure value0010 Application Regulation (EU) 2019/2033: K-TCD

Article 25(4), second subparagraph, of Regulation (EU) 2019/2033. Exposures for which the exposure value and the own funds requirements are determined in accordance with Regulation (EU) No 575/2013. 0070 Memorandum item: CVA component Articles 25(5) and 26 of Regulation (EU) 2019/2033. Where an institution applies the approach of Article 26 of Regulation (EU) 2019/2033 or applies the derogation of Article 26(5), first subparagraph, of Regulation of (EU) 2019/2033, the CVA component shall be determined as the difference between the relevant amount after the application of the CVA factor multiplier and the relevant amount before the application of the CVA factor multiplier. Where an institutions applies the derogation of the Article 25(5), second subparagraph of Regulation (EU) 2019/2033, the CVA component shall be determined in accordance with Part Three, Title VI, of Regulation (EU) No 575/2013. 0080 of which: calculated in accordance with Regulation (EU) No 575/2013 framework

Article 25(5), second subparagraph of Regulation (EU) 2019/2033. 0090 – 0110 Breakdown by type of counterparty The counterparty breakdown shall be based on the types of counterparties referred to in Table 2 in Article 26 of Regulation (EU) 2019/2033. 0090Central governments, central banks and public sector entities0100Credit institutions and investment firms0110Other counterpartiesColumnLegal references and instructions0010 K – factor requirement The own funds requirement shall be reported as calculated in accordance with Article 26 of Regulation (EU) 2019/2033 or the applicable provisions of Regulation (EU) No 575/2013. 0020 Exposure value The exposure value as calculated in accordance with Article 27 of Regulation (EU) 2019/2033 or the applicable provisions of Regulation (EU) No 575/2013. 0030 Replacement cost (RC)

Article 30(2) and (3) of Regulation (EU) 2019/2033. The value reported shall be the value of the collateral as used for the calculation of the exposure value and therefore, where applicable, the value after the application of the volatility adjustment and the currency mismatch volatility adjustment of Articles 30(1) and (3) of Regulation (EU) 2019/2033. 3.13. I 06.12– DAILY TRADING FLOW- ADDITIONAL DETAILS (I 6.12) 3.13.1. Instructions concerning specific positions RowLegal references and instructions0010 Total DTF – cash trades (average amounts) Investment firms shall report the arithmetic mean amount of DTF – cash trades for the remaining six months according with Article 33(1), first subparagraph of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 33(2), point (a), of Regulation (EU) 2019/2033. The amount reported in this cell shall take into account Article 33(3) of Regulation (EU) 2019/2033. 0020 Total DTF – derivative trades (average amounts)

Article 33(2), point (b), of Regulation (EU) 2019/2033. Investment firms shall report the arithmetic mean amount of DTF – derivative trades for the remaining six months according with Article 33(1), first subparagraph, of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 33(2), point (b), of Regulation (EU) 2019/2033. The amount reported in this cell shall take into account Article 33(3) of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010 Average factor amount – Month t Value of DTF as of the end of the third month (i.e. the most recent) of the quarter the report refers to. 0020 Average factor amount – Month t-1 Value of DTF as of the end of the second month of the quarter the report refers to. 0030 Average factor amount – Month t-2 Value of DTF as of the end of the first month of the quarter the report refers to. 3.14. I 06.13– AVERAGE VALUE OF TOTAL DAILY TRADING FLOWS (I 6.13) 3.14.1 Instructions concerning specific positions RowLegal references and instructions0010 Daily trading flow – cash trades The average value of the total daily trading flow (cash value) of the relevant month as referred to in Article 33(1) of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 33(2), point (a), of Regulation (EU) 2019/2033. 0020 Daily trading flow – derivative trades The average value of the total daily trading flow (derivative trades) of the relevant month as referred to in Article 33(1) of Regulation (EU) 2019/2033 and shall be measured pursuant to Article 33(2), point (b), of Regulation (EU) 2019/2033. ColumnsLegal references and instructions0010-0080 Monthly averages of total daily trading flow values Investment firms shall report in each relevant month column, the monthly average value of the total daily trading flow measured throughout each business day as per Article 33(1) of Regulation (EU) 2019/2033. 4. CONCENTRATION RISK REPORTING 4.1. General Remarks 16. Concentration risk reporting contains information about the concentration risks an investment firm is exposed to through its trading book positions due to the default of counterparties. This leads in to the calculation of K-CON, an additional own funds requirement due to the exposures the investment firm has on its balance sheet. This is in line with the definition of concentration risk in Article 4(1), point (31), of Regulation (EU) 2019/2033 where: concentration risk or CON means the exposures in the trading book of an investment firm to a client or a group of connected clients the value of which exceeds the limits in Article 37(1). 17. Concentration risk reporting also includes information about the following: i. Client money ii. Client assets iii. Firm’s own cash iv. Earnings from clients v. Trading book positions vi. Exposures calculated taking into account assets and off-balance sheet items not recorded in the trading book. 18. Although the wording in Article 54(2) of Regulation (EU) 2019/2033 also refers to concentration risk, the definition of this included in Article 4(1), point (31), of Regulation (EU) 2019/2033 and the limits set out Article 37(1) of Regulation (EU) 2019/2033 are not compatible with the items described in Article 54(2), points (b) to (e), of Regulation (EU) 2019/2033. For this reason, the reporting required focuses on the five largest positions, if available, in respect of each of items (i) to (vi) of paragraph 19 that are held at, or are attributable to, a particular institution, client or other entity. This reporting allows competent authorities to better understand the risks that investment firms might face from these.

1. Concentration risk reporting consists of the I 07.00 and I 08.00 templates and, in accordance with Article 54(2) of Regulation (EU) 2019/2033, firms that meet the conditions for qualifying as a small and non-interconnected investment firm set out in Article 12(1) of Regulation (EU) 2019/2033 are not required to report information in this regard. 4.2. I 07.00 – K-CON ADDITIONAL DETAILS (I7) 4.2.1. Instructions concerning specific positions ColumnsLegal references and instructions0010-0060 Counterparty ID The investment firm shall report the identification of the counterparties or group of connected clients to which they have an exposure that exceeds the limits set out in Article 37(1) of Regulation (EU) 2019/2033. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or ‘National code type. The type of code shall always be reported. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected clients is reported. In any other case, the name shall correspond to the individual counterparty. 0040 Group/individual The investment firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Counterparty type The investment firm shall report for each exposure if this is associated to:
2. a credit institution or a group of connected clients that includes a credit institution;
3. an investment firm or a group of connected clients that includes an investment firm;
4. Other than credit institutions or investment firms or group of connected clients that include an investment firm or an institution 0060-0110 Trading Book Exposures exceeding the limits set in Article 37(1) of Regulation (EU) 2019/2033 The investment firm shall report information on each exposure exceeding the limits set out in Article 37(1) of Regulation (EU) 2019/2033 in accordance with Article 36 and 39 of Regulation (EU) 2019/2033. 0060 Exposure Value (EV)

Article 36 of Regulation (EU) 2019/2033. 0070 Exposure Value (as % of Own Funds) Exposure calculated in accordance with Article 36 of Regulation (EU) 2019/2033 and expressed as a percentage of the firm’s own funds. 0080 Own Funds Requirement of total exposure (OFR) Own funds requirement of total exposure to the individual counterparty or group of connected clients, calculated as the total amount of K-TCD and of the specific risk requirement for K-NPR for the relevant exposure. 0090 Exposure Value Excess (EVE) Amount calculated in accordance with Article 37(2), second subparagraph, of Regulation (EU) 2019/2033 for the relevant exposure. 0100 Duration of the Excess (in days) Number of days passed since the exposure excess has first occurred. 0110 K-CON Own Funds Requirement for the Excess (OFRE) Amount calculated in accordance with Article 39(2) of Regulation (EU) 2019/2033 for the relevant exposure. 4.3. I 08.01 – LEVEL OF CONCENTRATION RISK – CLIENT MONEY HELD (I 8.1) 4.3.1. Instructions concerning specific columns ColumnsLegal references and instructions0010-0060 Total CMH

Article 54(2), point (b), of Regulation (EU) 2019/2033. The investment firm shall report the identification of the five, if available, counterparties or group of connected counterparties where the largest amounts of client money are held. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or National code type. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected counterparties is reported. In any other case, the name shall correspond to the individual counterparty. 0040 Group/individual The firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Total CMH at reporting date The firm shall report the total amount of client money at reporting date. 0060 Percentage of client money held at this institution The firm shall report the amount of client money held at reporting date with each of the counterparties or groups of connected counterparties for which reporting is made, expressed as a percentage of the total (reported in column 0050). 4.4. I 08.02 – LEVEL OF CONCENTRATION RISK – ASSETS SAFEGUARDED AND ADMINISTERED (I 8.2) 4.4.1. Instructions concerning specific columns ColumnsLegal references and instructions0010-0060 Total ASA

Article 54(2), point (c), of Regulation (EU) 2019/2033. The firm shall report the identification of the five, if available, counterparties or group of connected counterparties where the largest amounts of client securities are deposited. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or National code type. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected counterparties is reported. In any other case, the name shall correspond to the individual counterparty. 0040 Group/individual The firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Total ASA at reporting date The firm shall report the total amount of client securities deposited at each institution at reporting date. 0060 Percentage of client securities deposited at this institution The firm shall report the amount of client securities deposited at reporting date with each of the counterparties or groups of connected counterparties for which reporting is made, expressed as a percentage of the total (reported in column 0050). 4.5. I 08.03 – LEVEL OF CONCENTRATION RISK -TOTAL OWN CASH DEPOSITED (I 8.3) 4.5.1. Instructions concerning specific columns ColumnsLegal references and instructions0010-0060 Total Own Cash Deposited

Article 54(2), points (d) and (f), of Regulation (EU) 2019/2033. The firm shall report the identification of the five, if available, counterparties or group of connected counterparties where the largest amounts of firm’s own cash are deposited. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or National code type. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected counterparties is reported. In any other case, the name shall correspond to the individual counterparty. 0040 Group/individual The firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Amount of firm’s cash deposits at the institution The firm shall report the total amount of own cash held at each institution at the reference date. 0060 Percentage of firm’s own cash deposits at the institution The firm shall report the amount of own cash deposited at reporting date with each of the counterparties or groups of connected counterparties for which reporting is made, expressed as a percentage of the total own cash of the investment firm. 4.6. I 08.04 – LEVEL OF CONCENTRATION RISK – TOTAL EARNINGS (I 8.4) 4.6.1. Instructions concerning specific columns ColumnsLegal references and instructions0010-0080 Total Earnings

Article 54(2), points (e) and (f), of Regulation (EU) 2019/2033. The firm shall report the identification of the five, if available, clients or group of connected clients from whom the largest amounts of firm’s earnings are derived. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or National code type. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected clients is reported. In any other case, the name shall correspond to the individual client. 0040 Group/individual The firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Total earnings from this client The firm shall report the total earnings per client or group of connected clients generated since the beginning of the accounting year. The earnings shall be broken down by interest and dividend income on one hand and fee and commission income and other income on the other hand. 0060 – 0090Interest and dividend income0060 Interest and dividend income – Amount generated from positions in the trading book Trading book as defined in Article 4(1), point (54), of Regulation (EU) 2019/2033. 0070Interest and dividend income – Amount generated from positions in the non-trading book0080Interest and dividend income – of which: amount generated from off-balance sheet items0090 Percentage of interest and dividend income from this client The firm shall report the interest and dividend income generated from each of the clients or groups of connected clients, expressed as a percentage of the total interest and dividend income of the investment firm. 0100 – 0110Fee and commission and other income0100Fee and commission and other income – Amount0110 Percentage of fee and commission and other income from this client The firm shall report the fee and commission and other income generated from each of the clients or groups of connected clients, expressed as a percentage of the total fee and commission and other income of the investment firm. 4.7. I 08.05 – TRADING BOOK EXPOSURES (I 8.5) 4.7.1. Instructions concerning specific columns ColumnsLegal references and instructions0010-0050 Trading book exposures

Article 54(2), point (a), of Regulation (EU) 2019/2033. The firm shall report information in relation to the five, if available, largest trading book exposures. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or National code type. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected counterparties is reported. In any other case, the name shall correspond to the individual counterparty. 0040 Group/individual The firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Percentage of exposure to this counterparty with respect to firm’s own funds (trading book positions only) The firm shall report the trading book exposures at reporting date to each of the counterparties or groups of connected counterparties for which reporting is made expressed as a percentage of own funds. 4.8. I 08.06 – NON-TRADING BOOK AND OFF-BALANCE SHEET ITEMS (I 8.6) 4.8.1. Instructions concerning specific columns ColumnsLegal references and instructions0010-0050 Non-trading book and off-balance sheet items

Article 54(2), point (f), of Regulation (EU) 2019/2033. The firm shall report information in relation to the five, if available, largest exposures calculated including assets not recorded in the trading book. 0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The investment firms shall identify the type of code reported in column 0010 as a LEI code type or National code type. 0030 Name The name shall correspond to the name of the parent company whenever a group of connected counterparties is reported. In any other case, the name shall correspond to the individual counterparty. 0040 Group/individual The firm shall report 1 for the reporting of exposures to individual clients or 2 for the reporting of exposures to groups of connected clients. 0050 Percentage of exposure with respect to firm’s own funds (including off balance sheet assets and non-trading book items) The firm shall report exposures, calculated taking into account assets and off-balance sheet items not recorded in the trading book in addition to trading book positions, at reporting date to each of the counterparties or groups of connected counterparties for which reporting is made expressed as a percentage of eligible capital. 5. LIQUIDITY REQUIREMENTS 5.1 I 09.00 – LIQUIDITY REQUIREMENTS (I 9) 5.1.1. Instructions concerning specific positions RowLegal references and instructions0010 Liquidity Requirement

Article 43(1), point (c), of Regulation (EU) 2019/2033.

Annex

ANNEX III REPORTING FOR SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS INVESTMENT FIRMS TEMPLATESTemplate numberTemplate codeName of the template /group of templatesShort nameOWN FUNDS: level, composition, requirements and calculation1I 01.01Own fundsI1.12,3I 02.03Own funds requirementsI2.32,4I 02.04Capital ratiosI2.43,1I 03.01Fixed overheads requirements calculationI3.1SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS5I 05.00Level of activity - Thresholds reviewI5.0LIQUIDITY REQUIREMENTS9,1I 09.01Liquidity requirementsI9.1 I 01.01 - OWN FUNDS COMPOSITION (I1.1) RowsItemAmount00100010OWN FUNDS0020TIER 1 CAPITAL0030COMMON EQUITY TIER 1 CAPITAL0040Fully paid up capital instruments0050Share premium0060Retained earnings0070Previous years retained earnings0080Profit eligible0090Accumulated other comprehensive income0100Other reserves0110Minority interest given recognition in CET1 capital0120Adjustments to CET1 due to prudential filters0130Other funds0140(-)TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 10190(-) Losses for the current financial year0200(-) Goodwill0210(-) Other intangible assets0220(-) Deferred tax assets that rely on future profitability and do not arise from temporary differences net of associated tax liabilities 0230(-) Qualifying holding outside the financial sector which exceeds 15% of own funds0240(-) Total qualifying holdings in undertaking other than financial sector entities which exceeds 60% of its own funds0285(-) Other deductions0290CET1: Other capital elements, deductions and adjustments0300ADDITIONAL TIER 1 CAPITAL0310Fully paid up, directly issued capital instruments0320Share premium0330(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 10410Additional Tier 1: Other capital elements, deductions and adjustments0420TIER 2 CAPITAL0430Fully paid up, directly issued capital instruments0440Share premium0450(-) TOTAL DEDUCTIONS FROM TIER 20520Tier 2: Other capital elements, deductions and adjustments I 02.03 - OWN FUNDS REQUIREMENTS (I2.3) RowsItemAmount00100010Own Fund requirement0020Permanent minimum capital requirement0030Fixed overhead requirementTransitional own funds requirements0050Transitional requirement based on CRR own funds requirements0060Transitional requirement based on fixed overhead requirements0070Transitional requirement for investment firms previously subject only to an initial capital requirement0080Transitional requirement based on initial capital requirement at authorisation0090Transitional requirement for investment firms that are not authorised to provide certain servicesMemorandum items0110Additional own funds requirement0120Total own funds requirement I 02.04 - CAPITAL RATIOS (I2.4) AmountRowsItem00100010CET 1 Ratio0020Surplus(+)/Deficit(-) of CET 1 Capital0030Tier 1 Ratio0040Surplus(+)/Deficit(-) of Tier 1 Capital0050Own Funds Ratio0060Surplus(+)/Deficit(-) of Total capital I 03.01 - FIXED OVERHEADS REQUIREMENT CALCULATION (I3.1) AmountRowsItem00100010Fixed Overhead Requirement0020Annual Fixed Overheads of the previous year after distribution of profits0030Total expenses of the previous year after distribution of profits0040Of which: Fixed expenses incurred on behalf of the investment firms by third parties0050(-)Total deductions0060(-)Staff bonuses and other remuneration0070(-)Employees', directors' and partners' shares in net profits0080(-)Other discretionary payments of profits and variable remuneration0090(-)Shared commission and fees payable0100(-)Fees, brokerage and other charges paid to CCPs that are charged to customers0110(-)Fees to tied agents0130(-)Non-recurring expenses from non-ordinary activities0140(-)Expenditures from taxes0150(-)Losses from trading on own account in financial instruments0160(-)Contract based profit and loss transfer agreements0170(-)Expenditure on raw materials0180(-)Payments into a fund for general banking risk0190(-)Expenses related to items that have already been deducted from own funds0200Projected fixed overheads of the current year0210Variation of fixed overheads (%)

I 05.00 - LEVEL OF ACTIVITY - THRESHOLDS REVIEW (I5) AmountRowsItem00100010(Combined) assets under management0020(Combined) client orders handled - Cash trades0030(Combined) client orders handled - Derivatives0040Assets safeguarded and administered0050Client money held0060Daily trading flow - cash trades and derivative trades0070Net position risk0080Clearing margin given0090Trading counterparty default0100(Combined) on - and off-balance sheet total0110Combined total annual gross revenue0120Total annual gross revenue0130(-) Intragroup part of the annual gross revenue0140Of which: revenue from reception and transmission of orders0150Of which: revenue from execution of orders0160Of which: revenue from dealing on own account0170Of which: revenue from portfolio management0180Of which: revenue from investment advice0190Of which: revenue from underwriting of financial instruments/placing on a firm commitment basis0200Of which: revenue from placing without a firm commitment basis0210Of which: revenue from operation of an MTF0220Of which: revenue from operation of an OTF0230Of which: revenue from safekeeping and administration of financial instruments0240Of which: revenue from granting credits or loans to investors0250Of which: revenue from advice to undertakings on capital structure, industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings0260Of which: revenue from foreign exchange services0270Of which: investment research and financial analysis0280Of which: revenue from services related to underwriting0290Of which: investment services and ancillary activities related with the underlying of derivatives I 09.01 - LIQUIDITY REQUIREMENTS (I9.1) AmountRowsItem00100010Liquidity Requirement0020Client guarantees0030Total liquid assets

Annex

ANNEX IV REPORTING FOR SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS Table of contents PART I: GENERAL INSTRUCTIONS 114

1. Structure and conventions 114 1.1 Structure 114 1.2 Numbering convention 115 1.3 Sign convention 115 1.4 Prudential consolidation 115 PART II: TEMPLATE RELATED INSTRUCTIONS 115
2. OWN FUNDS: LEVEL, COMPOSITION, REQUIREMENTS AND CALCULATION 115 1.1 General Remarks 115 1.2. I 01.01 – OWN FUNDS COMPOSITION (I 1.1) 115 1.2.1. Instructions concerning specific positions 115 1.3 I 02.03 – OWN FUND REQUIREMENTS (I 2.3) 120 1.3.1. Instructions concerning specific positions 120 1.4. I 02.04 – CAPITAL RATIOS (I 2.4) 121 1.4.1. Instructions concerning specific positions 121 1.5. I 03.01 – FIXED OVERHEADS REQUIREMENT CALCULATION (I 3.1) 122 1.5.1. Instructions concerning specific positions 122
3. SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS 124 2.1. I 05.00 – LEVEL OF ACTIVITY – THRESHOLD REVIEW (I 5) 124 2.1.1. Instructions concerning specific positions 124
4. LIQUIDITY REQUIREMENTS 127 3.1 I 09.01 – LIQUIDITY REQUIREMENTS (I 9.1) 127 3.1.1. Instructions concerning specific positions 127 PART I: GENERAL INSTRUCTIONS
5. Structure and conventions 1.1 Structure

1. Overall, the framework consists of the following blocks of information: (a) Own funds; (b) Own funds requirements calculations; (c) Fixed overheads requirements calculation; (d) Level of activity in respect of the conditions set out in Article 12(1) of Regulation (EU) 2019/2033; (e) Liquidity requirements.
2. For each template, legal references are provided. Further detailed information regarding more general aspects of the reporting of each block of templates, instructions concerning specific positions as well as validation rules are included in this part of this Regulation. 1.2 Numbering convention
3. The document follows the labelling convention set in points 4 to 7, when referring to the columns, rows and cells of the templates. Those numerical codes are extensively used in the validation rules.
4. The following general notation is followed in the instructions: {Template; Row; Column}.
5. In the case of validations inside a template, in which only data points of that template are used, notations do not refer to a template: {Row; Column}.
6. In the case of templates with only one column, only rows are referred to. {Template; Row}
7. An asterisk sign is used to express that the validation is done for the rows or columns specified before. 1.3 Sign convention
8. Any amount that increases the own funds or own funds requirements, or the liquidity requirements, shall be reported as a positive figure. On the contrary, any amount that reduces the total own funds or own funds requirements shall be reported as a negative figure. Where there is a negative sign (-) preceding the label of an item no positive figure is expected to be reported of that item. 1.4 Prudential consolidation
9. Unless an exemption has been granted, Regulation (EU) 2019/2033 and Directive (EU) 2019/2034 apply to investment firms on an individual and on a consolidated basis, which includes reporting requirements in Part Seven of Regulation (EU) 2019/2033. Point (11) of Article 4(1) of Regulation (EU) 2019/2033 defines a consolidated situation as the result of applying the requirements of Regulation (EU) 2019/2033 to an investment firm group as if the entities of the group formed together a single investment firm. Following the application of Article 7 of the Regulation (EU) 2019/2033, investment firms groups shall fulfil the reporting requirements in all templates based on their scope of prudential consolidation (which may be different from their accounting consolidation scope). PART II: TEMPLATE RELATED INSTRUCTIONS
10. OWN FUNDS: LEVEL, COMPOSITION, REQUIREMENTS AND CALCULATION 1.1 General Remarks
11. Own funds overview section contains information about the own funds that an investment firm holds and its own funds requirements. It consists of two templates: (a) I 01.01 template contains the compositions of the own funds that an investment firm holds: Common Equity Tier 1 capital (CET1), Additional Tier 1 capital (AT1) and Tier 2 capital (T2). (b) I 02.03 and I 02.04 templates contain the total own funds requirement, the permanent minimum capital requirement, the fixed overheads requirement, any additional own funds requirement and guidance and the transitional own funds requirement and capital ratios.

(c) I 03.01 includes information with regard to the calculation of the Fixed overheads requirement. 11. The items in these templates are gross of transitional adjustments. This means that the figures (except where the transitional own funds requirement is specifically stated) are calculated according to the final provisions (i.e. as if there were no transitional provisions). 1.2. I 01.01 – OWN FUNDS COMPOSITION (I 1.1) 1.2.1. Instructions concerning specific positions RowLegal references and instructions0010 OWN FUNDS

Article 10(1), point (b) of Regulation (EU) 2019/2033. 0285 (-) Other deductions The sum of all other deductions in accordance with Article 36(1) of Regulation (EU) No 575/2013 that are not included in any of the rows 0160 to 0240 above 0290 CET1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered CET1 Capital instruments (Article 483, paragraphs 1, 2 and 3 and Articles 484 to 487 of Regulation (EU) No 575/2013) Transitional adjustments due to additional minority interests (Articles 479 and 480 of Regulation (EU) No 575/2013). Other transitional adjustments to CET1 Capital (Articles 469 to 478 and 481 of Regulation (EU) No 575/2013): adjustments to the deductions from CET1 due to transitional provisions. Other CET1 capital elements or deductions from a CET1 element that cannot be assigned to one of the rows 0040 to 0285. This row shall not be used to include capital items or deductions which are not covered by the Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios. 0300 ADDITIONAL TIER 1 CAPITAL

Article 56 of Regulation (EU) No 575/2013. 0410 Additional Tier 1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered AT1 Capital instruments (Article 483, paragraphs 4 and 5, Articles 484 to 487, Articles 489 and 491 of Regulation (EU) No 575/2013) Instruments issued by subsidiaries that are given recognition in AT1 Capital (Articles 83, 85 and 86 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying T1 capital of subsidiaries that is included in consolidated AT1, also including capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013) Transitional adjustments due to additional recognition in AT1 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013): adjustments to the qualifying T1 capital included in consolidated AT1 capital due to transitional provisions Other transitional adjustments to AT1 Capital (Articles 472, 473a, 474, 475, 478 and 481 of Regulation (EU) No 575/2013): adjustments to deductions due to transitional provisions Excess of deduction from AT1 items over AT1 Capital, deducted from CET1 in accordance with point (j) of Article 36(1) of Regulation (EU) No 575/2013: Additional Tier 1 cannot be negative, but it is possible that the deductions from AT1 items exceed the amount of available AT1 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0300 to zero and equals the inverse of the excess of deductions from AT1 items over AT1 Capital included, among other deductions, in row 0285. Other AT1 capital elements or deductions from an AT1 element that cannot be assigned to one of the rows 0310 to 0330. This row shall not be used to include capital items or deductions which are not covered by the Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios 0420 TIER 2 CAPITAL

Article 66 of Regulation (EU) No 575/2013. 0520 Tier 2: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered T2 Capital instruments (Article 483, paragraphs 6 and 7 of, Articles 484, 486, 488, 490 and 491 of Regulation (EU) No 575/2013) Instruments issued by subsidiaries that are given recognition in T2 Capital (Articles 83, 87 and 88 Regulation (EU) No 575/2013): Sum of all the amounts of qualifying own funds of subsidiaries that is included in consolidated T2, also including qualifying Tier 2 capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013) Transitional adjustments due to additional recognition in T2 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013): Adjustments to the qualifying own funds included in consolidated T2 capital due to transitional provisions. Other transitional adjustments to T2 Capital (Articles 472, 473a, 476, 477, 478 and 481 of Regulation (EU) No 575/2013): Adjustments to the deductions from Tier 2 due to transitional provisions Excess of deduction from T2 items over T2 Capital, deducted from AT1 in accordance with Article 56, point (e) of Regulation (EU) No 575/2013: Tier 2 cannot be negative, but it is possible that the deductions from T2 items exceed the amount of available T2 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0420 to zero. Other T2 capital elements or deductions from a T2 element that cannot be assigned to one of the rows 0430 to 0450. This row shall not be used to include capital items or deductions which are not covered by the Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios. 1.3 I 02.03 – OWN FUND REQUIREMENTS (I 2.3) 1.3.1. Instructions concerning specific positions RowLegal references and instructions0010 Own fund requirement

Article 40 of Directive (EU) 2019/2034. Additional own funds required following the SREP. 0120 Total own funds requirement The total own funds requirement of an investment firm shall consist of the sum of its own funds requirements applicable at the reference date, the additional own funds requirement as reported in row 0110 and the additional own funds guidance as reported in row 0120. 1.4. I 02.04 – CAPITAL RATIOS (I 2.4) 1.4.1. Instructions concerning specific positions RowLegal references and instructions0010 CET 1 Ratio

Article 9(1), point (c), Article 11(1) and (2) of Regulation (EU) 2019/2033. This item is expressed as a percentage. 0060 Surplus(+)/Deficit(-) of Total capital This item shows the surplus or deficit of own funds relating to the requirement set in Article 9(1) of Regulation (EU) 2019/2033. The transitional provisions of Article 57(3) and (4) of Regulation (EU) 2019/2033 shall not be considered for this item. 1.5. I 03.01 – FIXED OVERHEADS REQUIREMENT CALCULATION (I 3.1) 1.5.1. Instructions concerning specific positions RowLegal references and instructions0010 Fixed Overhead Requirement

Article 13(1) of Regulation (EU) 2019/2033. The amount reported shall be at least 25 % of the annual fixed overheads of the previous year (row 0020). In the cases where there is a material change as mentioned in Article 13(2) of Regulation (EU) 2019/2033, the amount reported shall be the fixed overheads requirement imposed by the competent authority in accordance with that Article. In the cases specified in Article 13(3) of Regulation (EU) 2019/2033, the amount to be reported shall be the projected fixed overheads of the current year (row 0200). 0020 Annual fixed overheads of the previous year after distribution of profits

Article 13 of Regulation (EU) 2019/2033. 0050 (-) Total deductions In addition to the items for deduction referred to in Article 13, point (4) of Regulation (EU) 2019/2033 the following items shall also be deducted from the total expenses, where they are included under total expenses in accordance with the relevant accounting framework: (a) fees, brokerage and other charges paid to central counterparties, exchanges and other trading venues and intermediate brokers for the purposes of executing, registering or clearing transactions, only where they are directly passed on and charged to customers. These shall not include fees and other charges necessary to maintain membership or otherwise meet loss-sharing financial obligations to central counterparties, exchanges and other trading venues; (b) interest paid to customers on client money, where there is no obligation of any kind to pay such interest; (c) expenditures from taxes where they fall due in relation to the annual profits of the investment firm; (d) losses from trading on own account in financial instruments; (e) payments related to contract-based profit and loss transfer agreements according to which the investment firm is obliged to transfer, following the preparation of its annual financial statements, its annual result to the parent undertaking; (f) payments into a fund for general banking risk in accordance with Article 26(1)(f) of Regulation (EU) No 575/2013; (g) expenses related to items that have already been deducted from own funds in accordance with Article 36(1) Regulation (EU) No 575/2013. 0060 (-) Staff bonuses and other remuneration

Article 13(4), point (a) of Regulation (EU) 2019/2033. Staff bonuses and other remuneration shall be considered to depend on the net profit of the investment firm in the respective year where both of the following conditions are met: (h) the staff bonuses or other remuneration to be deducted have already been paid to employees in the year preceding the year of payment, or the payment of the staff bonuses or other remuneration to employees will have no impact on the firm’s capital position in the year of payment; (i) with respect to the current year and future years, the firm is not obliged to award or allocate further bonuses or other payments in the form of remuneration unless it makes a net profit in that year. 0070 (-) Employees’, directors’ and partners’ shares in net profits

Article 13(4), point (d) of Regulation (EU) 2019/2033. 0100 (-) Fees, brokerage and other charges paid to CCPs that are charged to customers Fees, brokerage and other charges paid to central counterparties, exchanges and other trading venues and intermediate brokers for the purposes of executing, registering or clearing transactions, only where they are directly passed on and charged to customers. These shall not include fees and other charges necessary to maintain membership or otherwise meet loss-sharing financial obligations to central counterparties, exchanges and other trading venues. 0110 (-) Fees to tied agents

Article 13(4), point (f) of Regulation (EU) 2019/2033. 0140 (-) Expenditures from taxes Expenditures from taxes where they fall due in relation to the annual profits of the investment firm. 0150 (-) Losses from trading on own account in financial instruments Self-explanatory. 0160 (-) Contract based profit and loss transfer agreements Payments related to contract-based profit and loss transfer agreements according to which the investment firm is obliged to transfer, following the preparation of its annual financial statements, its annual result to the parent undertaking. 0170 (-) Expenditure on raw materials Commodity and emission allowance dealers may deduct expenditure on raw materials in connection with an investment firm trading in derivatives of the underlying commodity. 0180 (-)Payments into a fund for general banking risk Payments into a fund for general banking risk in accordance with Article 26(1)(f) of Regulation (EU) No 575/2013. 0190 (-)Expenses related to items that have already been deducted from own funds Expenses related to items that have already been deducted from own funds in accordance with Article 36(1) of Regulation (EU) No 575/2013. 0200 Projected fixed overheads of the current year The projection of the fixed overheads for the current year after the distribution of profits. 0210 Variation of fixed overheads (%) The amount shall be reported as the absolute value of: [(Annual fixed overheads of the current year) – (Projected fixed overheads of the previous year)/(Annual fixed overheads of the previous year)] 2. SMALL AND NON-INTERCONNECTED INVESTMENT FIRMS 2.1. I 05.00 – LEVEL OF ACTIVITY – THRESHOLD REVIEW (I 5) 2.1.1. Instructions concerning specific positions RowLegal references and instructions0010 (Combined) assets under management

Article 12(1), point (a) of Regulation (EU) 2019/2033. Where the reporting investment firm is part of a group, the value reported shall be determined on a combined basis for all investment firms that are part of a group pursuant Article 12(2) of Regulation (EU) 2019/2033. Investment firms shall include discretionary and non-discretionary assets under management. The amount reported shall be the amount that would be used for calculation of K-factors before application of relevant coefficients. 0020 (Combined) client orders handled – Cash trades

Article 12(1), point (i) of Regulation (EU) 2019/2033. Where the reporting investment firm is part of a group, the value reported shall be determined on a combined basis for all investment firms that are part of a group pursuant Article 12(2) of Regulation (EU) 2019/2033. The value reported shall be (row 0120 + row 0130). 0120 Total annual gross revenue The value of total annual gross revenue excluding the gross revenues generated within the group pursuant Article 12(2) of Regulation (EU) 2019/2033. 0130 (-) Intragroup part of the annual gross revenue The value of the gross revenues generated within the investment firm group pursuant Article 12(2) of Regulation (EU) 2019/2033. 0140 Of which:revenue from reception and transmission of orders

Article 45 of Regulation (EU) 2019/2033. The value reported shall be the 1,6 % of the total amount of guarantees provided to the clients pursuant Article 45 of Regulation (EU) 2019/2033. 0030 Total liquid assets Point (a) of Article 43(1) and Article 43(2) of Regulation (EU) 2019/2033. Total liquid assets shall be reported after application of relevant haircuts.

Annex

ANNEX V Part I: Single Data Point Model All data items set out in the Annexes to this Regulation shall be transformed into a single data point model, which is the basis for uniform IT systems of institutions and competent authorities. The single data point model shall meet the following criteria: (a) it provides a structured representation of all data items set out in Annex I, III and VIII; (b) it identifies all the business concepts set out in Annexes I to IV and VIII to IX; (c) it provides a data dictionary identifying table labels, ordinate labels, axis labels, domain labels, dimension labels and member labels; (d) it provides metrics, which define the property or amount of data points; (e) it provides data point definitions that are expressed as a composition of characteristics that univocally identify the concept; (f) it contains all the relevant technical specifications necessary for developing IT reporting solutions producing uniform supervisory data. Part II: Validation rules The data items set out in the Annexes to this Regulation shall be subject to validation rules ensuring data quality and consistency. The validation rules shall meet the following criteria: (a) they define the logical relationships between relevant data points; (b) they include filters and preconditions that define a set of data to which a validation rule applies; (c) they check the consistency of the reported data; (d) they check the accuracy of the reported data; (e) they set default values, which shall be applied where the relevant information has not been reported.

Annex

ANNEX VI DISCLOSURE ON OWN FUNDS TEMPLATES INVESTMENT FIRMS DISCLOSURETemplate numberTemplate codeNameLegislative referenceOWN FUNDS1I CC1COMPOSITION OF REGULATORY OWN FUNDSArt 49(1)(c)2I CC2OWN FUNDS RECONCILIATION WITH AUDITED FINANCIAL STATEMENTSArt 49(1)(a)3I CCAOWN FUNDS MAIN FEATURESArt 49(1)(b) Template EU IF CC1.01 - Composition of regulatory own funds (Iinvestment firms other than small and non-interconnected ) (a)(b)AmountsSource based on reference numbers/letters of the balance sheet in the audited financial statementsCommon Equity Tier 1 (CET1) capital: instruments and reserves1OWN FUNDS2TIER 1 CAPITAL3COMMON EQUITY TIER 1 CAPITAL4Fully paid up capital instruments5Share premium6Retained earnings7Accumulated other comprehensive income8Other reserves9Minority interest given recognition in CET1 capital10Adjustments to CET1 due to prudential filters11Other funds12(-)TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 113(-) Own CET1 instruments14(-) Direct holdings of CET1 instruments15(-) Indirect holdings of CET1 instruments16(-) Synthetic holdings of CET1 instruments17(-) Losses for the current financial year18(-) Goodwill19(-) Other intangible assets20(-) Deferred tax assets that rely on future profitability and do not arise from temporary differences net of associated tax liabilities21(-) Qualifying holding outside the financial sector which exceeds 15% of own funds22(-) Total qualifying holdings in undertaking other than financial sector entities which exceeds 60% of its own funds23(-) CET1 instruments of financial sector entites where the institution does not have a significant investment24(-) CET1 instruments of financial sector entities where the institution has a significant investment25(-)Defined benefit pension fund assets

26(-) Other deductions27CET1: Other capital elements, deductions and adjustments28ADDITIONAL TIER 1 CAPITAL29Fully paid up, directly issued capital instruments30Share premium31(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 132(-) Own AT1 instruments33(-) Direct holdings of AT1 instruments34(-) Indirect holdings of AT1 instruments35(-) Synthetic holdings of AT1 instruments36(-) AT1 instruments of financial sector entities where the institution does not have a significant investment37(-) AT1 instruments of financial sector entities where the institution has a significant investment38(-) Other deductions39Additional Tier 1: Other capital elements, deductions and adjustments40TIER 2 CAPITAL41Fully paid up, directly issued capital instruments42Share premium43(-) TOTAL DEDUCTIONS FROM TIER 244(-) Own T2 instruments45(-) Direct holdings of T2 instruments46(-) Indirect holdings of T2 instruments47(-) Synthetic holdings of T2 instruments48(-) T2 instruments of financial sector entities where the institution does not have a significant investment49(-) T2 instruments of financial sector entities where the institution has a significant investment50Tier 2: Other capital elements, deductions and adjustments Template EU IF CC1.02 - Composition of regulatory own funds (Small and non-interconnected investment firms) (a)(b)AmountsSource based on reference numbers/letters of the balance sheet in the audited financial statementsCommon Equity Tier 1 (CET1) capital: instruments and reserves1OWN FUNDS2TIER 1 CAPITAL3COMMON EQUITY TIER 1 CAPITAL4Fully paid up capital instruments5Share premium6Retained earnings7Accumulated other comprehensive income8Other reserves9Adjustments to CET1 due to prudential filters10Other funds11(-)TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 112(-) Losses for the current financial year13(-) Goodwill14(-) Other intangible assets15(-) Deferred tax assets that rely on future profitability and do not arise from temporary differences net of associated tax liabilities16(-) Qualifying holding outside the financial sector which exceeds 15% of own funds17(-) Total qualifying holdings in undertaking other than financial sector entities which exceeds 60% of its own funds18(-) Other deductions19CET1: Other capital elements, deductions and adjustments20ADDITIONAL TIER 1 CAPITAL21Fully paid up, directly issued capital instruments22Share premium23(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 124Additional Tier 1: Other capital elements, deductions and adjustments 25TIER 2 CAPITAL26Fully paid up, directly issued capital instruments27Share premium28(-) TOTAL DEDUCTIONS FROM TIER 229Tier 2: Other capital elements, deductions and adjustments Template EU IF CC1.03 - Composition of regulatory own funds (Group capital test) (a)(b)AmountsSource based on reference numbers/letters of the balance sheet in the audited financial statementsCommon Equity Tier 1 (CET1) capital: instruments and reserves1OWN FUNDS2TIER 1 CAPITAL3COMMON EQUITY TIER 1 CAPITAL4Fully paid up capital instruments5Share premium6Retained earnings7Previous years retained earnings8Profit or loss eligible9Accumulated other comprehensive income10Other reserves11Adjustments to CET1 due to prudential filters12Other funds13(-)TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 114(-) Own CET1 instruments15(-) Losses for the current financial year16(-) Goodwill17(-) Other intangible assets

18(-) Deferred tax assets that rely on future profitability and do not arise from temporary differences net of associated tax liabilities19(-) Qualifying holding outside the financial sector which exceeds 15% of own funds20(-) Total qualifying holdings in undertaking other than financial sector entities which exceeds 60% of its own funds21(-) CET1 instruments of financial sector entites where the institution does not have a significant investment22(-) Defined benefit pension fund assets23(-) Other deductions24CET1: Other capital elements, deductions and adjustments25ADDITIONAL TIER 1 CAPITAL26Fully paid up, directly issued capital instruments27Share premium28(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 129(-) Own AT1 instruments30(-) AT1 instruments of financial sector entities where the institution does not have a significant investment31(-) Other deductions32Additional Tier 1: Other capital elements, deductions and adjustments33TIER 2 CAPITAL34Fully paid up, directly issued capital instruments35Share premium36(-) TOTAL DEDUCTIONS FROM TIER 237(-) Own T2 instruments38(-) T2 instruments of financial sector entities where the institution does not have a significant investment39Tier 2: Other capital elements, deductions and adjustments Template EU ICC2: Own funds: reconciliation of regulatory own funds to balance sheet in the audited financial statements Flexible template. Rows have to be reported in line with the balance sheet included in the audited financial statements of the investment firm. Columns shall be kept fixed, unless the investment firm has the same accounting and regulatory scope of consolidation, in which case the volumes have to be entered in column (a) only. abcBalance sheet as in published/audited financial statementsUnder regulatory scope of consolidationCross reference to EU IF CC1As at period endAs at period endAssets - Breakdown by asset classes according to the balance sheet in the published/audited financial statements12345xxxTotal AssetsLiabilities - Breakdown by liability classes according to the balance sheet in the published/auditied financial statements1234xxxTotal LiabilitiesShareholders' Equity123xxxTotal Shareholders' equity Template EU I CCA: Own funds: main features of own instruments issued by the firm aFree text1Issuer2Unique identifier (e.g. CUSIP, ISIN or Bloomberg identifier for private placement)3Public or private placement4Governing law(s) of the instrument5Instrument type (types to be specified by each jurisdiction)6Amount recognised in regulatory capital (Currency in million, as of most recent reporting date)7Nominal amount of instrument8Issue price9Redemption price10Accounting classification11Original date of issuance12Perpetual or dated13Original maturity date14Issuer call subject to prior supervisory approval15Optional call date, contingent call dates and redemption amount16Subsequent call dates, if applicableCoupons / dividends17Fixed or floating dividend/coupon18Coupon rate and any related index19Existence of a dividend stopper20Fully discretionary, partially discretionary or mandatory (in terms of timing)21Fully discretionary, partially discretionary or mandatory (in terms of amount)22Existence of step up or other incentive to redeem23Noncumulative or cumulative24Convertible or non-convertible25If convertible, conversion trigger(s)26If convertible, fully or partially27If convertible, conversion rate28If convertible, mandatory or optional conversion29If convertible, specify instrument type convertible into30If convertible, specify issuer of instrument it converts into31Write-down features32If write-down, write-down trigger(s)33If write-down, full or partial34If write-down, permanent or temporary35If temporary write-down, description of write-up mechanism36Non-compliant transitioned features37If yes, specify non-compliant features38Link to the full term and conditions of the intrument (signposting)(1) Insert N/A if the question is not applicable

Annex

ANNEX VII INSTRUCTIONS FOR OWN FUNDS DISCLOSURE TEMPLATES Template EU I CC1.01, EU I CC1.02 and EU I CC1.03 – Composition of regulatory own funds

1. Investment firms shall apply the instructions provided in this Annex in order to complete template EU I CC1 as presented in Annex VI according to Article 49(1), points (a), and (c), of Regulation (EU) 2019/2033.
2. Investment firms shall complete column (b) to explain the source of every major input, which is to be cross-referenced to the corresponding rows in Template EU I CC2.
3. Investment firms shall include in the narrative accompanying the template a description of all restrictions applied to the calculation of own funds in accordance with Article 49(1) point (c), of Regulation (EU) 2019/2033 and the instruments and deductions to which those restrictions apply. They shall also explain the main changes in the amounts disclosed compared with previous disclosure periods.
4. This template is fixed, and investment firms shall disclose it with exactly the same format provided in Annex VI.
5. Investment firms other than small and non-interconnected shall disclose the information on composition of own funds in accordance with Template EU I CC1.01 in Annex VI. Small and non-interconnected investment firms with Additional Tier 1 instruments issuances shall disclose the information on composition of own funds in accordance with Template EU I CC1.02 also in Annex VI. Template EU I CC1.01 – Composition of regulatory own funds (Investment firms other than small and non-interconnected) Legal references and instructionsRowLegal references and instructions1 Own funds

Article 9(1) of Regulation (EU) 2019/2033. The own funds of an investment firm shall consist of the sum of its Common equity Tier 1 Capital, Additional Tier 1 Capital and Tier 2 Capital. This row is the sum of rows 2 and 40. 2 Tier 1 capital The Tier 1 capital is the sum of Common Equity Tier 1 Capital and Additional Tier 1 capital. This row is the sum of rows 3 and 28. 3 Common Equity Tier 1 capital

Article 36(1), point (e), of Regulation (EU) No 575/2013. 26 (-) Other deductions The sum of any other deductions listed in Article 36(1) of Regulation (EU) No 575/2013. 27 CET1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered CET1 Capital instruments (Article 483, paragraphs 1, 2 and 3 and Articles 484 to 487 of Regulation (EU) No 575/2013). Transitional adjustments due to additional minority interests (Articles 479 and 480 of Regulation (EU) No 575/2013). Other transitional adjustments to CET1 Capital (Articles 469 to 478 and 481 of Regulation (EU) No 575/2013): adjustments to the deductions from CET1 due to transitional provisions. Other CET1 capital elements or deductions from a CET1 element that cannot be assigned to one of the rows 4 to 26. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 28 ADDITIONAL TIER 1 CAPITAL

Article 56, point (d), of Regulation (EU) No 575/2013. 38 (-) Other deductions The sum of all other deductions in accordance with Article 56 of Regulation (EU) No 575/2013 that are not included in any of the rows above. 39 Additional Tier 1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered AT1 Capital instruments (Article 483, paragraphs 4 and 5, Articles 484 to 487, Articles 489 and 491 of Regulation (EU) No 575/2013). Instruments issued by subsidiaries that are given recognition in AT1 Capital (Articles 83, 85 and 86 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying T1 capital of subsidiaries that is included in consolidated AT1, also including capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013). Transitional adjustments due to additional recognition in AT1 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013) adjustments to the qualifying T1 capital included in consolidated AT1 capital due to transitional provisions. Other transitional adjustments to AT1 Capital (Articles 472, 473a, 474, 475, 478 and 481 of Regulation (EU) No 575/2013): adjustments to deductions due to transitional provisions. Excess of deduction from AT1 items over AT1 Capital, deducted from CET1 in accordance with Article 36(1), point (j), of Regulation (EU) No 575/2013: Additional Tier 1 cannot be negative, but it is possible that the deductions from AT1 items exceed the amount of available AT1 items. Where this happens, this item represents the amount needed to increase the amount reported in row 28 to zero and equals the inverse of the excess of deductions from AT1 items over AT1 Capital included, among other deductions, in row 38. Other AT1 capital elements or deductions from AT1 element that cannot be assigned to one of the rows 29 to 38. This row shall not be used to include capital items or deductions which are not covered by the Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 40 TIER 2 CAPITAL

Article 4(1), point (27), Article 66, point (d), Articles 68, 69 and Article 79 of Regulation (EU) No 575/2013. Holdings by the institution of T2 instruments of financial sector entities (as defined in Article 4(1), point (27), of Regulation (EU) No 575/2013) where the investment firm has a significant investment shall be completely deducted. 50 Tier 2: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered T2 Capital instruments (Article 483, paragraphs 6 and 7, Articles 484, 486, 488, 490 and 491 of Regulation (EU) No 575/2013). Instruments issued by subsidiaries that are given recognition in T2 Capital (Articles 83, 87 and 88 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying own funds of subsidiaries that is included in consolidated T2, also including qualifying Tier 2 capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013). Transitional adjustments due to additional recognition in T2 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013): Adjustments to the qualifying own funds included in consolidated T2 capital due to transitional provisions. Other transitional adjustments to T2 Capital (Articles 472, 473a, 476, 477, 478 and 481 of Regulation (EU) No 575/2013): Adjustments to the deductions from Tier 2 due to transitional provisions. Excess of deduction from T2 items over T2 Capital, deducted from AT1 in accordance with Article 56 of Regulation (EU) No 575/2013, point (e): Tier 2 cannot be negative, but it is possible that the deductions from T2 items exceed the amount of available T2 items. Where this happens, this item represents the amount needed to increase the amount reported in row 40 to zero. Other T2 capital elements or deductions from a T2 element that cannot be assigned to one of the rows 41 to 49. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. Template EU I CC1.02 – Composition of regulatory own funds (Small and non-interconnected investment firms) Legal references and instructionsRowLegal references and instructions1 Own funds

Article 9(1) of Regulation (EU) 2019/2033. The own funds of an investment firm shall consist of the sum of its Common equity Tier 1 Capital, Additional Tier 1 Capital and Tier 2 Capital. The total sum of rows 2 and 25 shall be disclosed. 2 Tier 1 capital The Tier 1 capital is the sum of Common Equity Tier 1 Capital and Additional Tier 1 capital. The total sum of rows 3 and 20 shall be disclosed. 3 Common Equity Tier 1 capital

Article 10(1), point (a), of Regulation (EU) 2019/2033. 18 (-) Other deductions The sum of any other deductions listed in Article 36(1) of Regulation (EU) No 575/2013. 19 CET1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered CET1 Capital instruments (Article 483, paragraphs 1, 2 and 3 and Articles 484 to 487 of Regulation (EU) No 575/2013). Transitional adjustments due to additional minority interests (Articles 479 and 480 of Regulation (EU) No 575/2013). Other transitional adjustments to CET1 Capital (Articles 469 to 478 and 481 of Regulation (EU) No 575/2013): adjustments to the deductions from CET1 due to transitional provisions. Other CET1 capital elements or deductions from a CET1 element that cannot be assigned to one of the rows 4 to 18. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 20 ADDITIONAL TIER 1 CAPITAL

Article 56 of Regulation (EU) No 575/2013. 24 Additional Tier 1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered AT1 Capital instruments (Article 483, paragraphs 4 and 5, Articles 484 to 487, Articles 489 and 491 of Regulation (EU) No 575/2013). Instruments issued by subsidiaries that are given recognition in AT1 Capital (Articles 83, 85 and 86 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying T1 capital of subsidiaries that is included in consolidated AT1, also including capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013). Transitional adjustments due to additional recognition in AT1 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013) adjustments to the qualifying T1 capital included in consolidated AT1 capital due to transitional provisions Other transitional adjustments to AT1 Capital (Articles 472, 473a, 474, 475, 478 and 481 of Regulation (EU) No 575/2013): adjustments to deductions due to transitional provisions. Excess of deduction from AT1 items over AT1 Capital, deducted from CET1 in accordance with Article 36(1), point (j), of Regulation (EU) No 575/2013: Additional Tier 1 cannot be negative, but it is possible that the deductions from AT1 items exceed the amount of available AT1 items. Where this happens, this item represents the amount needed to increase the amount reported in row 20 to zero and equals the inverse of the excess of deductions from AT1 items over AT1 Capital included, among other deductions, in row 18. Other AT1 capital elements or deductions from an AT1 element that cannot be assigned to one of the rows 21 to 23. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 25 TIER 2 CAPITAL

Article 66 of Regulation (EU) No 575/2013. 30 Tier 2: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered T2 Capital instruments (Article 483, paragraphs 6 and 7 of, Articles 484, 486, 488, 490 and 491 of Regulation (EU) No 575/2013). Instruments issued by subsidiaries that are given recognition in T2 Capital (Articles 83, 87 and 88 of Regulation (EU) No 575/2013): Sum of all the amounts of qualifying own funds of subsidiaries that is included in consolidated T2, also including qualifying Tier 2 capital issued by a special purpose entity (Article 83 of Regulation (EU) No 575/2013). Transitional adjustments due to additional recognition in T2 Capital of instruments issued by subsidiaries (Article 480 of Regulation (EU) No 575/2013): Adjustments to the qualifying own funds included in consolidated T2 capital due to transitional provisions. Other transitional adjustments to T2 Capital (Articles 472, 473a, 476, 477, 478 and 481 of Regulation (EU) No 575/2013): Adjustments to the deductions from Tier 2 due to transitional provisions. Excess of deduction from T2 items over T2 Capital, deducted from AT1 in accordance with Article 56, point (e), of Regulation (EU) No 575/2013: Tier 2 cannot be negative, but it is possible that the deductions from T2 items exceed the amount of available T2 items. Where this happens, this item represents the amount needed to increase the amount reported in row 25 to zero. Other T2 capital elements or deductions from a T2 element that cannot be assigned to one of the rows 26 to 28. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. Template EU I CC1.03 – Composition of regulatory own funds (Group capital test) 6. Entities referred to in Article 8(3) of Regulation (EU) 2019/2033 that are benefitting from the application of that same Article shall disclose the information on composition of own funds in accordance with template EU I CC1.03 and with the following instructions. RowLegal references and instructions1 OWN FUNDS

Article 36(1), point (e), of Regulation (EU) No 575/2013. 23 (-) Other deductions The sum of any other deductions listed in Article 36(1) of Regulation (EU) No 575/2013. 24 CET1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered CET1 Capital instruments (Article 483, paragraphs 1, 2 and 3 and Articles 484 to 487 of Regulation (EU) No 575/2013). Other transitional adjustments to CET1 Capital (Articles 469 to 478 and 481 of Regulation (EU) No 575/2013): adjustments to the deductions from CET1 due to transitional provisions. Other CET1 capital elements or deductions from a CET1 element that cannot be assigned to one of the rows 4 to 23. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 25 ADDITIONAL TIER 1 CAPITAL

Article 56, point (c), of Regulation (EU) No 575/2013. 31 (-) Other deductions The sum of all other deductions in accordance with Article 56 of Regulation (EU) No 575/2013, with the exception of the deductions in accordance with Article 56 of Regulation (EU) No 575/2013, point (d), that are not included in any of the rows 0340 or 0380 above. 32 Additional Tier 1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered AT1 Capital instruments (Article 483, paragraphs 4 and 5, Articles 484 to 487, Articles 489 and 491 of Regulation (EU) No 575/2013). Other transitional adjustments to AT1 Capital (Articles 472, 473a, 474, 475, 478 and 481 of Regulation (EU) No 575/2013): adjustments to deductions due to transitional provisions. Excess of deduction from AT1 items over AT1 Capital, deducted from CET1 in accordance with Article 36(1), point (j), of Regulation (EU) No 575/2013: Additional Tier 1 cannot be negative, but it is possible that the deductions from AT1 items exceed the amount of available AT1 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0300 to zero and equals the inverse of the excess of deductions from AT1 items over AT1 Capital included, among other deductions, in row 23. Other AT1 capital elements or deductions from AT1 element that cannot be assigned to one of the rows 26 to 31. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 33 TIER 2 CAPITAL

Article 63, point (b)(i), Article 66, point (a), and Article 67 of Regulation (EU) No 575/2013. Own T2 instruments held by the reporting institution or group at the reporting date. Subject to exceptions in Article 67 of Regulation (EU) No 575/2013. Holdings on shares included as Capital instruments not eligible shall not be disclosed in this row. The amount to be disclosed shall include the share premium related to the own shares. 38 (-) T2 instruments of financial sector entities where the institution does not have a significant investment

Article 66, point (c), of Regulation (EU) No 575/2013. 39 Tier 2: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered T2 Capital instruments (Article 483, paragraphs 6 and 7, Articles 484, 486, 488, 490 and 491 of Regulation (EU) No 575/2013). Other transitional adjustments to T2 Capital (Articles 472, 473a, 476, 477, 478 and 481 of Regulation (EU) No 575/2013): Adjustments to the deductions from Tier 2 due to transitional provisions. Excess of deduction from T2 items over T2 Capital, deducted from AT1 in accordance with Article 56, point (e), of Regulation (EU) No 575/2013: Tier 2 cannot be negative, but it is possible that the deductions from T2 items exceed the amount of available T2 items. Where this happens, this item represents the amount needed to increase the amount reported in row 33 to zero. Other T2 capital elements or deductions from a T2 element that cannot be assigned to one of the rows 34 to 38. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. Template EU I CC2 – Reconciliation of regulatory own funds to balance sheet in the audited financial statements 7. Investment firms shall apply the instructions provided in this Annex in order to complete template EU I CC2 as presented in Annex VI, in accordance with Article 49(1) point (a), of Regulation (EU) 2019/2033. 8. Investment firms shall disclose the balance sheet included in their published financial statements. Financial statements shall be the audited financial statements for the year-end disclosures. 9. The rows of the template are flexible and shall be disclosed by investment firms in line with their financial statements. Own funds items in the audited financial statements shall include all items that are components of or are deducted from regulatory own funds, including equity, liabilities such as debt, or other balance sheet lines that affect regulatory own funds such as intangible assets, goodwill, deferred tax assets. Investment firms shall expand the own funds items of the balance sheet as necessary in order to ensure that all of the components included in the composition of own funds disclosure template (template EU I CC1) appear separately. Investment firms shall only expand elements of the balance sheet up to the level of granularity that is necessary for deriving the components required by template EU I CC1. Disclosure shall be proportionate to the complexity of the investment firm’s balance sheet. 10. The columns are fixed and shall be disclosed as follows: a. Column a: Investment firms shall include the figures reported in the balance sheet included in their audited financial statements according to the accounting scope of consolidation. b. Column b: Investment firms shall report the figures corresponding to the regulatory scope of consolidation.

c. Column c: Investment firms shall include the cross-reference between the own funds item in template EU I CC2 and the relevant items in the own funds disclosure template EU I CC1. The reference in column c of template EU I CC2 will be linked to the reference included in column b of template EU I CC1. 11. In the following cases where investment firms’ scope of accounting consolidation and its scope of regulatory consolidation are exactly the same, only column (a) shall be filled and this fact shall be clearly disclosed: d. Where investment firms comply with the obligations laid down in Part Six of Regulation (EU) 2019/2033 on the prudential requirements of investment firms on a consolidated basis but the scope of consolidation and the method for consolidation used for the balance sheet in the financial statements are identical to the scope of consolidation and the method for consolidation defined pursuant to Part One, Title II, Chapter 2 of Regulation (EU) 2019/2033, and investment firms clearly state the absence of differences between the respective scopes and methods for consolidation in accompanying narrative to the template. e. Where investment firms meet the obligations laid down in Part Six of Regulation (EU) 2019/2033 on an individual basis. Table EU I CCA – Main features of own instruments issued by the firm. 12. Investment firms shall apply the instructions provided in this Annex in order to complete table EU I CCA as presented in Annex VI, according to Article 49(1) point (b), of Regulation (EU) 2019/2033. 13. Investment firms shall complete table EU I CCA for the following categories: Common Equity Tier 1 instruments, Additional Tier 1 instruments and Tier 2 instruments. 14. The tables shall comprise separate columns with the features of each regulatory own fund instruments. In cases where different instruments of a same category have identical features, investment firms may complete only one column disclosing these identical features and identify the issuances to which the identical features refer. Instructions for completing the own funds instruments issued by the firm main features tableRow numberExplanation1 Issuer Identifies issuer legal entity. Free text 2 Unique identifier (e.g. CUSIP, ISIN or Bloomberg identifier for private placement) Unique identifier (e.g. CUSIP, ISIN or Bloomberg identifier for private placement). Free text 3 Public or private placement Specifies if the instrument has been publicly or privately placed. Select from menu: [Public] [Private] 4 Governing law(s) of the instrument Specifies the governing law(s) of the instrument. Free text 5 Instrument type (types to be specified by each jurisdiction) Specifies instrument type, varying by jurisdiction. For CET1 instruments, select name of the instrument in the CET1 list published by the EBA. For other instruments, select from: menu options to be provided to investment firms by each jurisdiction – legal references of Regulation (EU) 2019/2033 articles for each type of instrument to be inserted.

6 Amount recognised in regulatory capital (Currency in million, as of most recent reporting date) Specifies the amount recognised in regulatory own funds (total amount of the instrument recognised before transitional provisions for the relevant level of the disclosure – currency used for the reporting obligations). Free text – specify in particular if some parts of the instruments are in different tiers of the regulatory own funds and if the amount recognised in regulatory own funds is different from the amount issued. 7 Nominal amount of instrument Nominal amount of instrument (in currency of issuance and currency used for the reporting obligations). Free text 8 Issue price Issue price of instrument. Free text 9 Redemption price Redemption price of instrument. Free text 10 Accounting classification Specifies accounting classification. Select from menu: [Shareholders’ equity] [Liability – amortised cost] [Liability – fair value option] [Non-controlling interest in consolidated subsidiary] 11 Original date of issuance Specifies date of issuance. Free text 12 Perpetual or dated Specifies whether dated or perpetual. Select from menu: [Perpetual] [Dated] 13 Original maturity date For dated instrument, specifies original maturity date (day, month and year). For perpetual instrument put no maturity. Free text 14 Issuer call subject to prior supervisory approval Specifies whether there is an issuer call option (all types of call options). Select from menu: [Yes] [No] 15 Optional call date, contingent call dates and redemption amount For instrument with issuer call option, specifies first date of call if the instrument has a call option on a specific date (day, month and year) and, in addition, specifies whether the instrument has a tax and/or regulatory event call. Also specifies the redemption price. Helps to assess permanence. Free text 16 Subsequent call dates, if applicable Specifies the existence and frequency of subsequent call dates, if applicable. Helps to assess permanence. Free text 17 Fixed or floating dividend/coupon Specifies whether the coupon/dividend is: either fixed over the life of the instrument, or floating over the life of the instrument, or currently fixed but will move to a floating rate in the future, or currently floating but will move to a fixed rate in the future. Select from menu: [Fixed], [Floating] [Fixed to floating], [Floating to fixed] 18 Coupon rate and any related index Specifies the coupon rate of the instrument and any related index that the coupon/dividend rate references. Free text 19 Existence of a dividend stopper Specifies whether the non-payment of a coupon or dividend on the instrument prohibits the payment of dividends on common shares (i.e. whether there is a dividend stopper). Select from menu: [yes], [no] 20 Fully discretionary, partially discretionary or mandatory (in terms of timing) Specifies whether the issuer has full discretion, partial discretion or no discretion over whether a coupon/dividend is paid. If the institution has full discretion to cancel coupon/dividend payments under all circumstances it must select fully discretionary (including when there is a dividend stopper that does not have the effect of preventing the institution from cancelling payments on the instrument). If there are conditions that must be met before payment can be cancelled (e.g. own funds below a certain threshold), the institution must select partially discretionary. If the institution is unable to cancel the payment outside of insolvency, the institution must select mandatory.

Select from menu: [Fully discretionary] [Partially discretionary] [Mandatory] Free text (specify the reasons for discretion, existence of dividend pushers, dividend stoppers, ACSM – Alternative Coupon Satisfaction Mechanism) 21 Fully discretionary, partially discretionary or mandatory (in terms of amount) Specifies whether the issuer has full discretion, partial discretion or no discretion over the amount of the coupon/dividend. Select from menu: [Fully discretionary] [Partially discretionary] [Mandatory] 22 Existence of step up or other incentive to redeem Specifies whether there is a step-up or other incentive to redeem. Select from menu: [Yes] [No] 23 Non-cumulative or cumulative Specifies whether dividends/coupons are cumulative or noncumulative. Select from menu: [Noncumulative] [Cumulative] [ACSM] 24 Convertible or non-convertible Specifies whether instrument is convertible or not. Select from menu: [Convertible] [Nonconvertible] 25 If convertible, conversion trigger(s) Specifies the conditions under which the instrument will convert, including point of non-viability. Where one or more authorities have the ability to trigger conversion, the authorities shall be listed. For each of the authorities it shall be stated whether it is the terms of the contract of the instrument that provide the legal basis for the authority to trigger conversion (a contractual approach) or whether the legal basis is provided by statutory means (a statutory approach). Free text 26 If convertible, fully or partially Specifies whether the instrument will always convert fully, may convert fully or partially, or will always convert partially. Select from menu: [Always Fully] [Fully or Partially] [Always partially] 27 If convertible, conversion rate Specifies rate of conversion into the more loss-absorbing instrument. Free text 28 If convertible, mandatory or optional conversion For convertible instruments, specifies whether conversion is mandatory or optional. Select from menu: [Mandatory] [Optional] [NA] and [at the option of the holders] [at the option of the issuer] [at the option of both the holders and the issuer] 29 If convertible, specify instrument type convertible into For convertible instruments, specifies instrument type convertible into. Select from menu: [Common Equity Tier 1] [Additional Tier 1] [Tier 2] [Other] 30 If convertible, specify issuer of instrument it converts into If convertible, specify issuer of instrument it converts into. Free text 31 Write-down features Specifies whether there is a write down feature. Select from menu: [Yes] [No] 32 If write-down, write-down trigger(s) Specifies the triggers at which write-down occurs, including point of non-viability. Where one or more authorities have the ability to trigger write-down, the authorities shall be listed. For each of the authorities it shall be stated whether it is the terms of the contract of the instrument that provide the legal basis for the authority to trigger write-down (a contractual approach) or whether the legal basis is provided by statutory means (a statutory approach).

Free text 33 If write-down, full or partial Specifies whether the instrument will always be written down fully, may be written down partially, or will always be written down partially. Helps assess the level of loss absorbency at write-down. Select from menu: [Always Fully] [Fully or Partially] [Always partially] 34 If write-down, permanent or temporary For write down instrument, specifies whether write down is permanent or temporary. Select from menu: [Permanent] [Temporary] [NA] 35 If temporary write-down, description of write-up mechanism Describes the write-up mechanism. Free text 36 Non-compliant transitioned features Specification if there are non-compliant features. Select from [yes] or [no]. 37 If yes, specify non-compliant features If there are non-compliant features, institution shall specify which ones. Free text 38 Link to the full term and conditions of the instrument (signposting) Investment firms shall include the hyperlink that gives access to the prospectus of the issuance, including all the terms and conditions of the instrument.

Annex

ANNEX VIII REPORTING ON GROUP CAPITAL TEST INVESTMENT FIRMS TEMPLATESTemplate numberTemplate codeName of the template /group of templatesShort nameGROUP CAPITAL TEST11,1I 11.01OWN FUNDS COMPOSITION - GROUP CAPITAL TESTI11.111,2I 11.02OWN FUND INSTRUMENTS - GROUP CAPITAL TESTI11.211,3I 11.03INFORMATION ON SUBSIDIARIES UNDERTAKINGSI11.3 I 11.01 - OWN FUNDS COMPOSITION - GROUP CAPITAL TEST (I11.1) RowsItemAmount00100010OWN FUNDS0020TIER 1 CAPITAL0030COMMON EQUITY TIER 1 CAPITAL0040Fully paid up capital instruments0050Share premium0060Retained earnings0070Previous years retained earnings0080Profit eligible0090Accumulated other comprehensive income0100Other reserves0120Adjustments to CET1 due to prudential filters0130Other funds0145(-)TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 10150(-) Own CET1 instruments0190(-) Losses for the current financial year0200(-) Goodwill0210(-) Other intangible assets0220(-) Deferred tax assets that rely on future profitability and do not arise from temporary differences net of associated tax liabilities0230(-) Qualifying holding outside the financial sector which exceeds 15% of own funds0240(-) Total qualifying holdings in undertaking other than financial sector entities which exceeds 60% of its own funds0250(-) CET1 instruments of financial sector entites where the investment firm does not have a significant investment0270(-) Defined benefit pension fund assets0280(-) Other deductions0295CET1: Other capital elements, deductions and adjustments0300ADDITIONAL TIER 1 CAPITAL0310Fully paid up, directly issued capital instruments 0320Share premium0335(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 10340(-) Own AT1 instruments0380(-) AT1 instruments of financial sector entities where the investment firm does not have a significant investment0400(-) Other deductions0415Additional Tier 1: Other capital elements, deductions and adjustments0420TIER 2 CAPITAL0430Fully paid up, directly issued capital instruments0440Share premium0455(-) TOTAL DEDUCTIONS FROM TIER 20460(-) Own T2 instruments0500(-) T2 instruments of financial sector entities where the parent does not have a significant investment0525Tier 2: Other capital elements, deductions and adjustments

I 11.02 - OWN FUND INSTRUMENTS - GROUP CAPITAL TEST (I11.2) AmountRowsItem00100010CET1 instruments of financial sector entities in the investment firm group where the parent undertaking has a significant investment in those entities0020AT1 instruments of financial sector entities in the investment firm group where the parent undertaking has a significant investment in those entities0030T2 instruments of financial sector entities in the investment firm group where the parent undertaking has a significant investment in those entities0040Holdings of financial sector entities in the investment firm group to the extent that they do not constitute own funds for the group entity the parent is invested in0050Subordinated claims of financial sector entities in the investment firm group0060Contingent liabilities in favour of entities in the investment firm group0070Total own fund requirements for the subsidiary undertakings I 11.03: INFORMATION ON SUBSIDIARIES UNDERTAKINGS (I11.3) CodeType of codeName of the undertakingParent / subsidiaryCountryInvestments by the parent undertakingContingent liabilities of the parent in favour of the entityTotal own fund requirementsCET1AT1T2HoldingsSubordinated claimsPermanent minimum capitalK-factor requirementFixed overhead requirementsAssets under managementClient money held - SegregatedClient money held - Non - segregatedAssets safeguarded and administeredClient orders handled - Cash tradesClient orders handled - Derivatives TradesK-Net positions risk requirementClearing margin givenTrading counterparty defaultDaily trading flow - Cash tradesDaily trading flow - Derivative tradesK-Concentration risk requirement001000200030004000500060007000800090010001100120013001400150016001700180019002000210022002300240025002600270

Annex

ANNEX IX REPORTING ON GROUP CAPITAL TEST Table of contents PART I: GENERAL INSTRUCTIONS 162

1. Structure and conventions 162 1.1 Structure 162 1.2 Numbering convention 162 1.3 Sign convention 162 PART II: TEMPLATE RELATED INSTRUCTIONS 163
2. OWN FUNDS: LEVEL, COMPOSITION, REQUIREMENTS AND CALCULATION 163 1.1 General Remarks 163 1.2. IF 11.01 – OWN FUNDS COMPOSITION – GROUP CAPITAL TEST (IF11.1) 163 1.2.1. Instructions concerning specific positions 163 1.3 IF 11.02 OWN FUNDS REQUIREMENTS – GROUP CAPITAL TEST (IF11.2) 169 1.3.1. Instructions concerning specific positions 169 1.4 IF 11.03 INFORMATION ON SUBSIDIARIES UNDERTAKINGS (IF11.3) 170 1.4.1. Instructions concerning specific positions 170 PART I: GENERAL INSTRUCTIONS
3. Structure and conventions 1.1 Structure
4. Overall, group capital test reporting consists of 2 templates: (a) Own funds composition (b) Own fund instruments.
5. For each template, legal references are provided. Further detailed information regarding more general aspects of the reporting of each block of templates, instructions concerning specific positions as well as validation rules are included in this part of this Regulation. 1.2 Numbering convention
6. The document follows the labelling convention set in points 4 to 7, when referring to the columns, rows and cells of the templates. Those numerical codes are extensively used in the validation rules.

1. The following general notation is followed in the instructions: {Template; Row; Column}.
2. In the case of validations inside a template, in which only data points of that template are used, notations do not refer to a template: {Row; Column}.
3. In the case of templates with only one column, only rows are referred to. {Template; Row}
4. An asterisk sign is used to express that the validation is done for the rows or columns specified before. 1.3 Sign convention
5. Any amount that increases the own funds or own funds requirements, or the liquidity requirements, shall be reported as a positive figure. On the contrary, any amount that reduces the total own funds or own funds requirements shall be reported as a negative figure. Where there is a negative sign (-) preceding the label of an item no positive figure is expected to be reported of that item. PART II: TEMPLATE RELATED INSTRUCTIONS
6. OWN FUNDS: LEVEL, COMPOSITION, REQUIREMENTS AND CALCULATION 1.1 General Remarks
7. Own funds overview section contains information about the own funds that an investment firm holds and its own funds requirements. It consists of two templates: (a) Template I 11.01 contains the compositions of the own funds that an investment firm holds: Common Equity Tier 1 capital (CET1), Additional Tier 1 capital (AT1) and Tier 2 capital (T2). (b) Template I 11.02 contains information on the own fund requirements in the context of the group capital test, i.e. intragroup holdings, contingent liabilities and total own funds requirements of the subsidiaries. (c) Template I 11.03 contains the relevant information on capital requirements, contingent liabilities, subordinated claims and holdings of financial sector entities at subsidiary level, broken down entity-by-entity.
8. The items in these templates are gross of transitional adjustments. This means that the figures (except where the transitional own funds requirement is specifically stated) are calculated according to the final provisions (i.e. as if there were no transitional provisions). 1.2. I 11.01 – OWN FUNDS COMPOSITION – GROUP CAPITAL TEST (I11.1) 1.2.1. Instructions concerning specific positions RowLegal references and instructions0010 OWN FUNDS

Article 36(1), point (e), of Regulation (EU) No 575/2013. 0280 (-) Other deductions The sum of all other deductions in accordance with Article 36(1) of Regulation (EU) No 575/2013, with the exception of deductions in accordance with Article 36(1), point (i), of Regulation (EU) No 575/2013, that are not included in any of the rows 0150 to 0270 above. 0295 CET1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered CET1 Capital instruments (Article 483, paragraphs 1, 2 and 3 and Articles 484 to 487 of Regulation (EU) No 575/2013). Other transitional adjustments to CET1 Capital (Articles 469 to 478 and 481 of Regulation (EU) No 575/2013): adjustments to the deductions from CET1 due to transitional provisions. Other CET1 capital elements or deductions from a CET1 element that cannot be assigned to one of the rows 0040 to 0280. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 0300 ADDITIONAL TIER 1 CAPITAL

Article 56, point (c), of Regulation (EU) No 575/2013. Union parent in this row means Union parent investment firms, Union parent investment holding companies, Union parent mixed financial holdings or any other parent undertaking that is an investment firms, financial institution, ancillary services undertaking or tied agent. 0400 (-) Other deductions The sum of all other deductions in accordance with Article 56 of Regulation (EU) No 575/2013, with the exception of the deductions in accordance with Article 56, point (d), of Regulation (EU) No 575/2013, that are not included in any of the rows 0340 or 0380 above. 0415 Additional Tier 1: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered AT1 Capital instruments (Article 483, paragraphs 4 and 5, Articles 484 to 487, Articles 489 and 491 of Regulation (EU) No 575/2013). Other transitional adjustments to AT1 Capital (Articles 472, 473a, 474, 475, 478 and 481 of Regulation (EU) No 575/2013): adjustments to deductions due to transitional provisions. Excess of deduction from AT1 items over AT1 Capital, deducted from CET1 in accordance with Article 36(1), point (j), of Regulation (EU) No 575/2013: Additional Tier 1 cannot be negative, but it is possible that the deductions from AT1 items exceed the amount of available AT1 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0300 to zero and equals the inverse of the excess of deductions from AT1 items over AT1 Capital included, among other deductions, in row 0280. Other AT1 capital elements or deductions from a AT1 element that cannot be assigned to one of the rows 0310 to 0400. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 in the calculation of the solvency ratios. 0420 TIER 2 CAPITAL

Article 63, point (b)(i), Article 66, point (a), and Article 67 of Regulation (EU) No 575/2013. Own T2 instruments held by the reporting institution or group at the reporting date. Subject to exceptions in Article 67 of Regulation (EU) No 575/2013. Holdings on shares included as Capital instruments not eligible shall not be reported in this row. The amount to be reported shall include the share premium related to the own shares. 0500 (-) T2 instruments of financial sector entities where the parent does not have a significant investment

Article 66, point (c), of Regulation (EU) No 575/2013. Union parent in this row means Union parent investment firms, Union parent investment holding companies, Union parent mixed financial holdings or any other parent undertaking that is an investment firms, financial institution, ancillary services undertaking or tied agent. 0525 Tier 2: Other capital elements, deductions and adjustments This row shall include the sum of the following items, where applicable: Transitional adjustments due to grandfathered T2 Capital instruments (Article 483, paragraphs 6 and 7, Articles 484, 486, 488, 490 and 491 of Regulation (EU) No 575/2013) Other transitional adjustments to T2 Capital (Articles 472, 473a, 476, 477, 478 and 481 of Regulation (EU) No 575/2013): Adjustments to the deductions from Tier 2 due to transitional provisions Excess of deduction from T2 items over T2 Capital, deducted from AT1 in accordance with Article 56, point (e), of Regulation (EU) No 575/2013: Tier 2 cannot be negative, but it is possible that the deductions from T2 items exceed the amount of available T2 items. Where this happens, this item represents the amount needed to increase the amount reported in row 0420 to zero Other T2 capital elements or deductions from a T2 element that cannot be assigned to one of the rows 0430 to 0500. This row shall not be used to include capital items or deductions which are not covered by Regulation (EU) 2019/2033 or Regulation (EU) No 575/2013 into the calculation of the solvency ratios. 1.3 I 11.02 OWN FUNDS REQUIREMENTS – GROUP CAPITAL TEST (I11.2) 1.3.1. Instructions concerning specific positions RowLegal references and instructions0010 CET1 instruments of financial sector entities in the investment firm group where the parent undertaking has a significant investment in those entities

Article 8(3), point (b), of Regulation (EU) 2019/2033. 0070 Total own fund requirements for the subsidiary undertakings In case of application of Article 8(4) of Regulation (EU) 2019/2033. 1.4 IF 11.03 INFORMATION ON SUBSIDIARIES UNDERTAKINGS (IF11.3) 10. All entities included in the scope of the group capital test shall be reported in this template. This shall also include the parent undertaking of the group itself. 1.4.1. Instructions concerning specific positions ColumnsLegal references and instructions0010 Code The code as part of a row identifier must be unique for each reported entity. For investment firms and insurance undertakings the code shall be the LEI code. For other entities the code shall be the LEI code, or if not available, a national code. The code shall be unique and used consistently across the templates and across time. The code shall always have a value. 0020 Type of code The reporting entity shall identify the type of code reported in column 0010 as a LEI code type or Nationalcode type. The type of code shall always be reported. 0030 Name of the undertaking Name of the undertaking within the scope of consolidation. 0040 Parent/subsidiary Indicates whether the entity reported in the row is the parent of the group or a subsidiary 0050 Country The country where the subsidiary is located shall be reported. 0060 – 0100 Investments by the parent undertaking

Article 26 and Article 24 of Regulation (EU) 2019/2033. 0240 Daily trading flow – Cash trades For the purposes of K-factor requirement calculation, investment firms shall report by applying the coefficient of Article 15(2) of Regulation (EU) 2019/2033. In the event of stressed market conditions, in accordance with Article 15(5), point (c), of Regulation (EU) 2019/2033, investment firms shall apply an adjusted coefficient as specified in that point. Daily trading flow factor shall be calculated in accordance with Article 33(2), point (a), of Regulation (EU) 2019/2033. 0250 Daily trading flow – Derivative trades For the purposes of K-factor requirement calculation, investment firms shall report by applying the coefficient of Article 15(2) of Regulation (EU) 2019/2033. In the event of stressed market conditions, in accordance with Article 15(5), point (c), of Regulation (EU) 2019/2033, investment firms shall apply an adjusted coefficient as specified in that point. Daily trading flow factor shall be calculated in accordance with Article 33(2), point (b), of Regulation (EU) 2019/2033. 0260 K-Concentration risk requirement