According to Annex XXI of Regulation (EU) 2021/451 – ITS on supervisory reporting, point 1, template C 71.00 'collects information about the reporting institutions’ concentration of counterbalancing capacity by the ten largest holdings of assets or liquidity lines granted to the institution'. In addition, point 3 clarifies that the 'counterbalancing capacity in C 71.00 shall be the same as that in C 66.01'. Point 6 further clarifies that 'concentrations of counterbalancing capacity with a central bank as issuer or counterparty shall not be reported in this template' as individual issuer.

Given the above, to the extent that the secured debt instruments issued by the reporting institution and retained are part of the counterbalancing capacity of the institution (e.g. they fall into the scope of C 66.01 reporting - initial stock - column 0010), the institution falls under the top 10 issuers and the instruments are unencumbered to be available for the institution to convert into cash on the reporting reference date, then the reporting institution shall be reported as the issuer of such instruments for the purpose of C 71.00. The product type to be reported would be the type of secured debt instruments that have been retained, in line with point 2 of Annex XXI.