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Deutscher Sparkassen- und Giroverband (DSGV, Register of Interest Representatives No. 62379064909-15)

In terms of C 74.00 ID 1.2 seq DSGV pleads for removing all 'of which' positions like 1.2.1.1.1.1 of which collateral received meets operational requirements" since the assets received could change every day. This fact leads in our opinion to reporting items showing a value of zero.

If our amendment should not be implemented we strongly ask for a clarification of what exactly to report including illustrative examples."
DSGV is of the opinion that in order to monitor the usage of the newly introduced waiver for the HQLA unwinding mechanism if the counterparty is a central bank template C75.00 should be altered in another fashion with minimal impact for the supervised institutions.

Item 1 TOTAL COLLATERAL SWAPS (counterparty is central bank)" should not distinguish between counterparties and hence should read "TOTAL COLLATERAL SWAPS (all counterparties)".

Item 2 "TOTAL COLLATERAL SWAPS (counterparty is non-central bank)" should be changed into an optional 'of which' position and hence should read "OF WHICH COLLATERAL SWAPS with counterparty is central bank (in case of using the waiver for the HQLA unwinding mechanism)"."
Leon Unger
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