We are reaching out regarding the Consultation Paper published by EBA on 22/05 concerning Pillar III ESG disclosures.

Specifically, we would kindly request clarification about the additional line required in Template 2 related to covered bonds:

"In addition, a breakdown for information on cover pool of covered bonds is requested in rows for the Total EU area and Total non-EU area (rows 1.1 and 6.1 respectively)."

As stated in the CP document:

“Following Recital 55 of the CRR3, the EBA is asked to assess means to enhance the disclosures on ESG risks of cover pools of covered bonds and to consider whether information on the relevant exposures of the pools of loans underlying covered bonds issued by institutions, either directly or through the transfer of loans to a special purpose vehicle (SPV), should either be included in the revised ITS or in the regulatory and disclosure framework for covered bonds”

We would appreciate your guidance on the following points:

• Should only the covered bonds issued by the institution reporting the template be considered?

Or does this also include covered bonds acquired from other institutions (other banks - in addition to the already mentioned SPVs)?

• Considering the scope of the template, the exposures to be reported refer to the loans collateralized by the immovable properties securing the bonds, and not the value of the bonds themselves, is that correct?

• Should the total amount be reconciled with a specific cell in the FINREP reporting framework?

Thank you in advance for your kind clarification.