2020 EBA data collection for investment firms - Instructions v1.0

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS - TEMPLATE INSTRUCTIONS 04 June 2020 Version 1.0 2020 EBA data collection exercise for investment firms Template instructions

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS Contents

1. Introduction 3
2. General instructions 4
   2.1 Scope of the exercise 4
   2.2 Timeline 4
   2.3 Filling in the data 5
   2.4 Process 10
   2.5 Reference date 11
   2.6 Structure of the Excel template 11
3. Template specific instructions 12
   3.1 Input 12
   3.2 General information 12
   3.3 CRR threshold EUR 30bn (CRR Article 4(1)(1b)) 19
   3.4 Current requirements 21
   3.5 IF 01.00 – Own funds composition (IF 1) 23
   3.6 IF 02.00 – Own funds requirements (IF 2) 23
   3.7 IF 03.00 – Fixed overheads requirement calculation (IF 3) 24
   3.8 IF 04.00 – Total K-factor requirement calculations (IF 4) 26
   3.9 Identified staff 29

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS

1. Introduction
   On December 5, 2019, the Investment Firm Regulation (IFR) 1 and the Investment Firm Directive (IFD) 2 were published in the Official Journal of the European Union. The IFR and IFD lay down uniform prudential requirements and supervision rules for investment firms authorised and supervised under Directive 2014/65/EU (MiFID) 3 . The IFR and IFD require the EBA to develop a series of draft RTS, including among others: a) 3 draft RTS on the thresholds and criteria for investment firms to be subject to CRR; b) 6 draft RTS on the capital requirements at individual and consolidated level; and c) 1 draft RTS on identifying staff whose professional activities have a material impact on an investment firm's risk profile for remuneration purposes. The purpose of this data collection is to assessthe impact of these draft RTS, which are published for consultation alongside the data collection. This document describes the template data items and gives instructions on how to fill them in. It should be read in conjunction with the IFR, IFD, Consultation Paper (CP) on draft RTS prudential requirements for investment firms (EBA/CP/2020/06) 4 and the CP on pay out in instruments for variable remuneration under IFD (EBA/CP/2020/09) . The descriptions of the items in these instructions intend to facilitate the completion of the template and shall not be construed as an official interpretation of the applicable regulation. If there are cases where the descriptions in this document contradict the requirements prescribed in the regulation or draft RTS, the latter should prevail. The EBA will treat all individual investment firm data collected in this exercise as strictly confidential and will not attribute them to individual investment firms. For the purposes of this document, Regulation (EU) 2019/2033 is referred to as ‘IFR’, Directive (EU) 2019/2034 is referred to as ‘IFD’, Directive 2014/65/EU is referred to as ‘MiFID’, Regulation (EU) No 575/2013 is referred to as ‘CRR’ and Directive (EU) No 2013/36 is referred to as ‘CRD’. The remainder of this document is organised as follows. Section 2 discusses general issues such as the scope, timeline and process of the data collection exercise, as well as the overall structure of the template. Section 3 provides template specific instructions for all worksheets.

Regulation (EU) 2019/2033 of the European Parliament and of the Council of 27 November 2019 on the prudential requirements of investment firms 2 Directive (EU) 2019/2034 of the European Parliament and of the Council of 27 November 2019 on the prudential supervision of investment firms 3 Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments CP on draft RTS prudential requirements for investment firms CP on draft RTS on pay out in instruments for variable remuneration under IFD

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
2. General instructions
2.1 Scope of the exercise
The participation in this data collection exercise is voluntary.
The EBA expects EEA investment firms as defined in point (22) of Article 4(1) of IFR, authorised and supervised under MiFID, to participate in this exercise. Where applicable and unless noted otherwise, data for investment firms shall be reported on an individual basis. The EBA further expects EEA investment firm groups that would be subject to prudential consolidation under Article 7 of the IFR to participate in this exercise. An investment firm group is a group which consists of at least one investment firm and which does not include a credit institution (point (25) of Article 4(1) IFR). Article 7 of the IFR prescribes that Union parent investment firms, Union parent investment holding companies and Union parent mixed financial holding companies shall comply with capital requirements on the basis of their consolidated situation. A consolidated situation is defined as the result of applying the requirements of IFR to an investment firm group as if the entities of the group formed together a single investment firm (point (11) of Article 4(1) of IFR). The scope of consolidation of an investment firm group is described in more detail in the draft RTS on prudential consolidation under IFR. Prudential consolidation shall be carried out at the highest level of EU consolidation, without sub-consolidation at lower levels of the group. Investment firms groups shall use this prudential scope to fulfil the reporting requirements in all templates, and not the scope of accounting consolidation that may be different. Where applicable and unless noted otherwise, data for investment firm groups shall be reported on a consolidated basis. Please note that Union parent investment firms are expected to submit two separate templates, one on an individual basis and one on a consolidated basis, respectively. The reporting scope used in each template (i.e. individual or consolidated) should be indicated in the “Input” worksheet.
2.2 Timeline
Table 1 shows the timeline of the data collection. Investment firms are required to submit the
completed templatesto their national competent authority (NCA) by 19 August 2020. Following the data quality assurance, the investment firms would be required to re-submit revised templates, addressing data quality issues, by 16 September 2020.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
Table 1 Timeline for the data collection exercise
04 June 2020
Launch of the data collection exercise
Publication and distribution of the final templates and instructions to investment firms (in parallel with CPs) 19 August 2020 Remittance date of the exercise and deadline for the first submission from investment firms to NCA 24 August 2020 – 4 September 2020 Data quality assurance 16 September 2020 Second submission and final deadline for investment firms to submit data revisions to the NCAs in case of data quality issues
2.3 Filling in the data
The exercise targets all investment firms and investment firm groups that are subject to consolidated requirements under IFR/IFD. However, some parts of the exercise are only relevant to certain types of investment firms, depending on their classification under the revised regulatory framework and their scope of reporting. The classification, which primarily depends on the investment firm’s total assets and carrying investment services and activities, would force certain investment firms to be subject to prudential requirements under the CRR/CRD instead of the IFR/IFD. As a result, the prudential requirements under IFR/IFD, and consequently the draft RTS, would not be applicable to those firms. To facilitate reporting, the template is organised in five types of worksheets, marked with a different colour:
 Content – grey colour: Template which gives general information on how to populate the templates and also indicates the version number of the file;  Basic – blue colour: Templates which request basic information necessary to process the data;  CRR thresholds – orange colour: Template which collects information on the thresholds to subject an investment firm to the requirements of the CRR;  IFR/IFD (main) – green colour: Templates which collect information on the overall prudential requirements under IFR/IFD;  IFR/IFD (extra) – red colour: Templates which collect information on the K-factor capital requirements as well as identified staff whose professional activities have a material impact on an investment firm's risk profile under IFR/IFD.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
Table 2 provides an overview of worksheets included in the template.
Table 2 Overview of the template
Colour Type Worksheet(s)
To be filled in
Individual basis Consolidated basis
Grey Content TOC N/A N/A
Blue Basic
Input ALL ALL
General Info ALL ALL
Orange CRR thresholds
CRR EUR
30bn Relevant investment firms NONE
Green IFR/IFD (main)
Current req a) Relevant investment firms which do NOT exceed any of the CRR thresholds (EUR 30bn, EUR 15bn) b) Investment firms other than relevant investment firms ALL IF1 IF2 IF3 Red IFR/IFD (extra) IF4 a) Relevant investment firms which do NOT exceed any of the CRR threshold (EUR 30bn, EUR 15bn) AND which are NOT deemed as small and non-interconnected b) Investment firms other than relevant investment firms which are NOT deemed as small and non￾interconnected Investment firm groups which are NOT deemed as small and non￾interconnected Identified staff Notes: 1) “Relevant investment firms” are those that carry out any of the activities referred to in points (3) and (6) of Section A of
Annex I to MiFID, but are not a commodity and emission allowance dealer, a collective investment undertaking or an insurance
undertaking.
2) “CRR thresholds” refer to the conditions an investment firm needs to meet to be subject to the CRR as those are specified in Article
4(1)(1b) of the CRR6
(EUR30bn) and point (a) or (b) of Article 1(2) of IFR (EUR15bn).
3) “Small and non-interconnected” investment firms or investment firm groups are those that meet all the conditions specified in
Article 12 of the IFR or Article 8(2) of the [draft RTS on prudential consolidation under IFR], respectively.
All reporting entities should complete the “Basic” type worksheets (marked with blue colour). The remaining worksheets should be completed according to an investment firm’s classification under the revised regulatory framework and its scope of reporting (individual, consolidated). Investment firms shall report their classification under the revised regulatory framework in the ‘General Info’ worksheet, Panel 5) Classification under the revised regulatory framework. It is very important that investment firms determine their classification correctly. In particular, investment firm should indicate if:
 they are a relevant investment firm,

As amended in Article 62 of the IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS  they exceed the CRR thresholds to be subject to the CRR/CRD, or  they are a small and interconnected investment firm. Relevant investment firms are those that carry out any of the activities referred to in points (3) and (6) of Section A of Annex I to MiFID, but are not a commodity and emission allowance dealer, a collective investment undertaking or an insurance undertaking. These investment firms would be subject to the CRR/CRD if they exceed any of the CRR thresholds. The CRR thresholds refer to the thresholds an investment firm needs to exceed to be subject to the CRR/CRD as those are specified in Article 4(1)(1b) of the CRR 7 (EUR 30bn) and point (a) or (b) of Article 1(2) of IFR (EUR 15bn). These thresholds are only relevant for investment firms reporting on an individual basis. Small and non-interconnected investment firms or investment firm groups are those that meet all the conditions specified in Article 12 of the IFR (at individual basis) or Article 8(2) of the [draft RTS on prudential consolidation under IFR] (at consolidated basis), respectively. When reporting on an individual basis,  Relevant investment firms should complete the “CRR thresholds” type of worksheet (marked with orange colour). o Relevant investment firms which exceed any of the CRR thresholds (EUR 30bn, EUR 15bn) are not required to fill in any additional worksheet. o Relevant investment firms which do not exceed any of the CRR thresholds (EUR 30bn, EUR 15bn) should fill in the “IFR/IFD” type of worksheets (marked with green and red colour). In particular, all these investment firms should fill in the “IFR/IFD (main)” type of worksheets (marked with green), while those investment firms which are not deemed small and non-interconnected should also fill in the “IFR/IFD (extra)” type of worksheet (marked with red colour).  Investment firms other than relevant investment firms, should fill in only the “IFR/IFD” type of worksheets (marked with green and red colour). In particular, all these investment firms should fill in the “IFR/IFD (main)” type of worksheets (marked with green), while those investment firms which are not deemed small and non-interconnected should also fill in the “IFR/IFD (extra)” type of worksheets (marked with red colour). None of these investment firms should fill in the “CRR thresholds” type of worksheet (marked with orange). When reporting on a consolidated basis,

As amended in Article 62(3) of the IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS  All investment firm groups should fill in the “IFR/IFD (main)” type of worksheets (marked with green).  Investment firm groups that are not deemed small and non-interconnected should also fill in the “IFR/IFD (extra)” type of worksheets (marked with red colour).  None of the investment firm groups should fill in the “CRR thresholds” type of worksheet (marked with orange). The information to determine if an investment firm is a relevant investment firm is collected in the worksheet “General info” Panel 5. Once the information is filled in, the memo box in column F would automatically show if an investment firm is considered as relevant or not (see cell ‘General info’!F52). The information to determine if an investment firm exceeds the CRR thresholds (EUR 30bn, EUR 15b) is collected in the worksheet “General info” Panel 5 and “CRR EUR 30bn”. Investment firms should manually assess if they exceed any of thresholds to be subject to the CRR as those are specified in Article 4(1)(1b) of the CRR 8 (EUR 30bn) and point (a) or (b) of Article 1(2) of IFR (EUR 15bn) and select the corresponding requirement from the drop down list (see ‘General info’!C55). The information to determine if an investment firm/investment firm group is deemed to be small and non-interconnected is collected in the worksheet “General info” Panel 5. Investment firms/investment firm groups should manually assess if they meet all the conditions specified in in Article 12 of the IFR to determine if they are deemed to be small and non-interconnected and select the corresponding requirement from the drop down list (see cell ‘General info’!C55).
Figure 1 provides a flowchart showing how individual investment firms and investment firm
groups should fill in the template.

As amended in Article 62 of the IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
Figure 1 Flow chart on how to fill in the template

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS Data should only be entered in the white cells. There are also some light orange cells which include formulas and must not be changed. It is important to note that any modification to the worksheets might render the workbook unusable both for the validation of the final results and the subsequent aggregation process. Where information is not available, the corresponding cell should be left empty. No text such as “na” should be entered in these cells. Also, investment firms must not fill in any arbitrary numbers to avoid error messages or warnings which may be provided by their NCA. However, leaving a cell empty could trigger exclusion from some or all of the analyses if the respective item is required. Data can be reported in the most convenient currency. The currency which has been used should be recorded in the “Input” worksheet (see Section 3.1). If 1,000 or 1,000,000 currency units are used for reporting, this should also be indicated in this worksheet. When choosing the reporting unit, it should be considered that the worksheet shows all amounts as integers. Unless noted otherwise, the same currency and unit should be used for all amounts throughout the workbook, irrespective of the currency of the underlying exposures. Percentages should be reported as decimals and will be converted to percentages automatically. For example, 1% should be entered as 0.01. 9 Where investment firms are required to provide text, investment firms should use English language and avoid revealing their identity in their responses. The EBA is aware that some investment firms might not yet have implemented some of the models and processes required for the calculations. In such cases, investment firms may provide quantitative data on a “best-efforts” basis. In case of doubt, they should discuss with the relevant national supervisor how to proceed. Unless noted otherwise, investment firms should only report data for the approach they are currently using or are intending to use. Cells provided for various approaches are in general intended to facilitate partial use and do not require investment firms to conduct alternative calculations for the same set of exposures.
2.4 Process
The EBA will not collect any data directly from investment firms. Therefore, investment firms should contact their competent authority to discuss how the completed workbooks should be submitted. Competent authorities will forward the relevant data to the EBA, where individual investment firm data will be treated as strictly confidential.

9 Depending on the regional options of the operating system used, it might be necessary to use a different decimal symbol. It might also be necessary to switch off the option “Enable automatic percent entry” in the Tools/Options/Edit dialog of Excel if percentages cannot be entered correctly.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS Similarly, investment firms should direct all questions related to this study, the related rules and consultation papers to their competent authority. Investment firms should specify any instance where they had to deviate from the instructions provided in an additional document.
2.5 Reference date
All data should be reported as of 31/12/2019. Where data at that date is not available, the most recent data should be submitted. In this case, the reference data used should be indicated in the worksheet “Input” (see Section 3.1).
2.6 Structure of the Excel template
The template consists of 10 worksheets. As explained in section 2.3 certain parts of the template are only relevant for some types of investment firms. The worksheets requiring data input are the following:
 The “Input” worksheet captures basic information on the investment firm’s identification, reporting data conventions and scope of reporting (individual or consolidated basis).  The “General Info” worksheet captures general information on the investment firm’s group structure and business, current and revised prudential requirements, and balance sheet information. This worksheet shall be filled in as a first step (i.e. after filling in the “Input” worksheet and before filling in any other worksheet), as the information provided in Panel 5 gives guidance on which worksheet need to be reported.  The “CRR EUR 30bn” worksheet collects information on the criteria to authorise an investment firm as credit institution according to Article 4(1)(1b) of the CRR 10 (EUR 30bn).  The “Current Req” worksheet captures eligible capital and current capital requirements.  The “IF1”worksheet captures eligible capital under IFR/IFD.  The “IF2” worksheet captures overall capital requirements under IFR/IFD.  The “IF3” worksheet captures the fixed overheads requirements under IFR/IFD.  The “IF4” worksheet captures the K-factor requirements under IFR/IFD.  The “Identified staff” worksheet collects information on the number of identified staff whose professional activities have a material impact on an investment firm's risk profile or assets it manages under IFD.

10 As amended in Article 62(3) of the IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3. Template specific instructions
3.1 Input
The “Input” worksheet containsinformation needed to process and interpret the data collection results. Legal references and instructions LEI code Legal Entity Identifier (LEI) code of the reporting entity. Entity name Name of the reporting entity. Country Country in which the investment firm is authorised under MiFID. In case of a Union parent investment holding companies or a Union parent mixed financial holding companies the country of incorporation. Scope of reporting Scope of consolidation (Individual, Consolidated) in which data are reported. Reference date Date as of which all data are reported in worksheets. Use the format dd/mm/yyyy. Data should be reported as of 31/12/2019. Where data at that date is not available, please submit the most recent data and indicate the reference date. Reporting currency Three-character ISO code of the currency in which all data are reported (e.g. EUR). Reporting unit Units (single currency units, thousands, millions) in which data are reported.
3.2 General information
The “General Info” worksheet contains general information on the investment firm participating in the data collection exercise.
3.2.1 Group structure
This panel collects basic information to understand the investment firm’s group structure.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS Row Legal references and instructions 0010 Investment firm is a single legal entity Please indicate (Yes/No) if the investment firm is a single legal entity, i.e. a stand￾alone entity, which does not belong to an EU group. A group is defined in point (13) of Article 3(1) of the IFD. 0020 Investment firm is part of an EU banking group Please indicate (Yes/No) if the investment firm is part, as parent or subsidiary, of an EU group that includes at least one credit institution. 0030 Investment firm is part of an EU investment firm group Please indicate (Yes/No) if the investment firm is part, as parent or subsidiary, of an EU investment firm group. An investment firm group is defined in point (25) of
Article 4(1) of the IFR.
0040 Investment firm will be subject to prudential consolidation under IFR/IFD Please indicate (Yes/No) if the investment firm will fall in the scope of prudential consolidation of an investment firm group in accordance with Article 7 of IFR. 0050 If yes, EU parent name If firm has selected ‘Yes’ in row 0040, please indicate the name of the EU consolidating parent (at highest level of EU consolidation) as per Article 7. If the investment firm in question is the Union parent investment firm/consolidating entity, row 0050 should be identical with the entity name in the worksheet ‘Input’. 0060 If yes, EU parent LEI code If firm has selected ‘Yes’ in row 0040, please indicate the LEI code of the EU consolidating parent (at highest level of EU consolidation) as per Article 7. If the investment firm in question is the Union parent investment firm/consolidating entity, row 0060 should be identical with the LEI code in the worksheet ‘Input’. 0070 Investment firm is part of a third country group Please indicate (Yes/No) if the investment firm is part of a third country group. A third country group is defined in point (6) of Article 2(1) of the [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)].

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3.2.2 Investment services/activities and business model
This panel collects information on the business of the investment firm. Row Legal references and instructions 0080 (1) Reception and transmission of orders in relation to one or more financial instruments Please indicate (Yes/No) if the investment firm is authorised to perform the investment service, which correspond to point (1) in the list in Annex I, section A, MiFID. 0090 (2) Execution of orders on behalf of clients Please indicate (Yes/No) if the investment firm is authorised to perform the investment service, which correspond to point (2) in the list in Annex I, section A, MiFID. 0100 (3) Dealing on own account Please indicate (Yes/No) if the investment firm is authorised to perform the investment activity, which correspond to point (3) in the list in Annex I, section A, MiFID. 0110 (4) Portfolio management Please indicate (Yes/No) if the investment firm is authorised to perform the investment service, which correspond to point (4) in the list in Annex I, section A, MiFID. 0120 (5) Investment advice Please indicate (Yes/No) if the investment firm is authorised to perform the investment service, which correspond to point (5) in the list in Annex I, section A, MiFID. 0130 (6) Underwriting of financial instruments and/or placing of financial instruments on a firm commitment basis Please indicate (Yes/No) if the investment firm is authorised to perform the investment service, which correspond to point (6) in the list in Annex I, section A, MiFID. 0140 (7) Placing of financial instruments without a firm commitment basis Please indicate (Yes/No) if the investment firm is authorised to perform the investment service, which correspond to point (7) in the list in Annex I, section A, MiFID. 0150 (8) Operation of an MTF Please indicate (Yes/No) if the investment firm is authorised to perform the investment activity, which correspond to point (8) in the list in Annex I, section A, MiFID. 0160 (9) Operation of an OTF Please indicate (Yes/No) if the investment firm is authorised to perform the investment activity, which correspond to point (9) in the list in Annex I, section A, MiFID.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS 0170 Is the investment firm permitted to hold client money or financial instruments belonging to clients? Please indicate (Yes/No) if the investment firm is permitted to hold client money or financial instruments belonging to clients to which the safeguarding arrangements under MiFID apply. 0180 If yes, does the investment firm comply with the requirements on safeguarding of client financial instruments and funds set out in paragraph 1 Article 2 of the Commission Delegated Directive (EU) 2017/593? If firm has selected ‘Yes’ in row 0170, please indicate (Yes/No) if the investment firm complies with the requirements on safeguarding of client financial instruments and funds set out in paragraph 1 of Article 2 of the Commission Delegated Directive (EU) 2017/593. 0190 If yes, does the investment firm comply with the requirements on safeguarding of client financial instruments and funds set out in paragraph 2 Article 2 of the Commission Delegated Directive (EU) 2017/593? If firm has selected ‘Yes’ in row 0170, please indicate (Yes/No) if the investment firm complies with the requirements on safeguarding of client financial instruments and funds set out in paragraph 2 of Article 2 of the Commission Delegated Directive (EU) 2017/593. 0200 If yes, does the investment firm comply with the requirements on safeguarding of client financial instruments and funds set out in paragraph 3 Article 2 of the Commission Delegated Directive (EU) 2017/593? If firm has selected ‘Yes’ in row 0170, please indicate (Yes/No) if the investment firm complies with the requirements on safeguarding of client financial instruments and funds set out in paragraph 3 of Article 2 of the Commission Delegated Directive (EU) 2017/593. 0210 Business model Please indicate the business model of the investment firm by selecting from the drop￾down list:

• Wholesale market brokers
• Multi-service investment firms
• Portfolio managers
• Investment advisors
• Trading firms
• Firms placing financial instruments on a firm commitment basis
• Execution brokers (including reception and transmission)
• MTF or OTF
• Custodians
• Commodity and emission allowance dealers

11 Commission Delegated Directive (EU) 2017/593 of 7 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council with regard to safeguarding of financial instruments and funds belonging to clients, product governance obligations and the rules applicable to the provision or reception of fees, commissions or any monetary or non-monetary benefits

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3.2.3 Current regulatory framework
This panel deals with the current regulatory framework of the investment firm. Row Legal references and instructions 0220 Is the investment firm subject to any EU regulatory requirements derived from the CRD and/or CRR? Please indicate (Yes/No) if the investment firm is subject to requirements derived from CRR or CRD. For reference, please refer to tables 2 and 3 of the December 2015 report on investment firms. 12 Please note that this question is different from “are you a CRR investment firm?” which covers only categories 5 to 9 & 11 in the 2015 Investment Firms Report (tables 2 and 3). 0230 If yes, please indicate to which CRR/CRD requirements the investment firm is subject to If the firm has selected ‘Yes’ in row 0220, please indicate to which CRD and/or CRR requirements the firm is subject to by selecting from the drop-down list:

• CRD 30 & CRR 4(1)(4)
• CRD 31(1) & CRR 4(1)(2)(c)
• CRD 31(2) & CRR 4(1)(2)(c)
• CRD 31(1) & CRR 95(2)
• CRD 29(1) & CRR 95(1)
• CRD 29(3) & CRR 95(1)
• CRD 28(2) & CRR 95(1)
• CRD 28(2) & CRR 96(1)(a)
• CRD 28(2) & CRR 96(1)(b)
• CRD 28 or CRD 29 & CRR 493 & 498
• CRD 28(2) & CRR 92
  For further guidance, please refer to tables 2 and 3 of the December 2015 report on investment firms. 13 0240 If no, is the investment firm subject to any other national provisions of prudential nature? If the firm has selected ‘No’ in row 0220, please indicate (Yes/No) if the firm is subject to any other national prudential requirements.

12 EBA/Op/2015/20 Report on investment firms responding to the Commission's Call for Advice of December 2014 13 EBA/Op/2015/20 Report on investment firms responding to the Commission's Call for Advice of December 2014

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3.2.1 Balance sheet information
This panel collects balance sheet information.
Row Legal references and instructions
0250 Accounting standard
Please indicate the accounting standard (IFRS, National GAAP) used.
0260 Total assets
Total assets. This should exclude assets under management but include client money and financial instruments belonging to clients, if on-balance sheet. When reporting data on a consolidated basis, total assets should be reported considering the prudential scope of consolidation.
3.2.2 Classification under the revised regulatory framework
This panel collects information on investment firm’s requirements and classification under the revised regulatory framework. Once an investment firm fills in this information, the memo box in cell F52 would determine automatically if an investment firm is relevant or not. It is very important that investment firms determine correctly to which own funds requirements they would be subject to under the revised regulatory framework. Row Legal references and instructions 0270 Is the investment firm carrying out the MiFID activity (3) Dealing on own account? Please indicate (Yes/No) if the investment firm is carrying out the investment activity, which correspond to point (3) in the list in Annex I, section A, MiFID. 0280 Is the investment firm carrying out the MiFID activity (6) Underwriting of financial instruments and/or placing of financial instruments on a firm commitment basis? Please indicate (Yes/No) if the investment firm is carrying out the investment activity, which corresponds to point (6) in the list in Annex I, section A, MiFID. 0290 Is the undertaking a commodity and emission allowance dealer? Please indicate (Yes/No) if the investment firm is a commodity and emission allowance dealer as defined in point (5) of Article 4(1) of the IFR. 0300 Is the undertaking a collective investment undertaking or an insurance undertaking? Please indicate (Yes/No) if the investment firm is a collective investment undertaking or an insurance undertaking defined in point (7) and point (5) of Article 4(1) of the CRR, respectively. 0310 Please indicate to which own funds requirements would the investment firm be subject to under the revised regulatory framework? Please indicate to which prudential requirements the investment firm will be subject to under the revised regulatory framework:

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS

• CRR/CRD according to Art 4(1)(1b) CRR as amended by Art 62(3) IFR
  (CRR threshold EUR 30bn)
• CRR/CRD according to point (a) or (b) of Art 1(2) IFR (CRR threshold EUR
  15bn)
• IFR/IFD according to Art 11(2) & 12 IFR (Small and non-interconnected)
• IFR/IFD according to Art 11(1) IFR (K-factors)
  0320 Will the investment firm meet the criteria under point (a) and (b) of Art 5(1) IFD as further specified in [Draft RTS to further specify criteria for the discretion of competent authorities to subject certain investment firms to the CRR]? Please indicate “Yes” if the investment firm meets both the following criteria:
• carries out any of the activities listed in points (3) and (6) of Section A of
  Annex I to MiFID and the total value of its consolidated assets equal to or
  exceed EUR 5bn (see Art 5(1) IFD first paragraph); and
• the criteria in point (a) or (b) of the Art 5(1) IFD apply, as those are further
  specified in Article 1 and 2 of the [Draft RTS to further specify criteria for the discretion of competent authorities to subject certain investment firms to the CRR], respectively.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3.3 CRR threshold EUR 30bn (CRR Article 4(1)(1b))
The “CRR EUR 30bn” worksheet collects information to assess if an investment firm exceeds the EUR 30bn thresholds as prescribed in Article 4(1)(1b) of the CRR 14 and would be subject to the CRR/CRD. Investment firms are asked to calculate consolidated assets using two alternative methodologies:
 Baseline scenario: Investment firms should rely on all the provisions prescribed in the [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)].  Alternative scenario: Investment firms should rely on all the provisions prescribed in the [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)], except for the definition of “intragroup exposures” defined in point (8) of Article 2(1) of that RTS, where an alternative definition should be used (see below for details). Rows Legal references and instructions Information about the reporting entity 0010 Total assets Total assets of the undertaking as determined on the basis of the prudential individual reporting of financial information to the competent authority in accordance with applicable law or requirements. 0020 Total consolidated assets Consolidated assets of the undertaking as determined in accordance with Chapter 4 of [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)]. This data item should be calculated under two scenarios: the baseline and the alternative scenario (see below for details). Information about the group the entity belongs to 0030 Total value of consolidated assets of relevant undertakings in the group CTAu as calculated in accordance with Article 10 of [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)]. This data item should be calculated under two scenarios: the baseline and the alternative scenario (see below for details). 0040 Total value of individual assets of subsidiaries outside the EU The sum of the individual assets ('IA’ as referred to in the formula of Article 9 of [Draft RTS on the methodology for calculating the EUR 30bn threshold required to

14 As amended by Art 62(3) IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS be authorised as a credit institution (Article 8a(6) point b) of the CRD)]) of the entities defined in point (c) of Article 8(1) of that [Draft RTS]. 0050 Total value of individual assets of relevant EU branches of the third-country parent ∑ 𝑇𝐴𝑇𝐶𝐵𝑗 𝑁 𝑗=1 as referred to in the formula of Article 10 of [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)]. Columns Legal references and instructions 0010 Baseline scenario: Average over past 12 months
Article 11(1) of [Draft RTS on the methodology for calculating the EUR 30bn
threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)]. When calculating consolidated assets (rows 0020, 0030), investment firms should rely on all the provisions prescribed in the [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)], including the definition of “intragroup exposures” defined in point (8) of Article 2(1) of that [draft RTS]. 0050 Alternative scenario for intragroup exposures definition: Average over past 12 months
Article 11(1) of [Draft RTS on the methodology for calculating the EUR 30bn
threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)]. When calculating consolidated assets (rows 0020, 0030), investment firms should rely on all the provisions prescribed in the [Draft RTS on the methodology for calculating the EUR 30bn threshold required to be authorised as a credit institution (Article 8a(6) point b) of the CRD)], except for the definition of “intragroup exposures” defined in point (8) of Article 2(1) of that [draft RTS], where the below alternative definition should be used:
‘intragroup exposure’ means any exposure that occur between a relevant institution and its parent undertaking, other subsidiaries of that parent undertaking, or its own subsidiaries, including adjustments made according to ultimate parent’s accounting policies in order to calculate assets to be included in the consolidated balance sheet.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3.4 Current requirements
The “Current Req” worksheet collects information on the current Pillar 1 numerators (own funds, Tier 1, Common Equity Tier 1) and denominator (own funds requirements) under the applicable regulatory framework.
3.4.1 Own funds
This panel contains the amount of own funds of the investment firms, disaggregated in the items needed to get to that amount. The amount of own funds obtained includes the aggregate effect of transitional provisions per type of capital. The total own funds consist of different types of capital: Tier 1 capital (T1), which is the sum of Common Equity Tier 1 capital (CET1) and Additional Tier 1 capital (AT1), as well as Tier 2 capital (T2). Transitional provisions are treated as follows. The items in this panel are gross of transitional adjustments. This means that figures in the items in this panel are calculated according to the final provisions (i.e. as if there were no transitional provisions). Transitional provisions may also affect the AT1 and the T2 shortfall (i.e. AT1 or T2 excess of deduction, regulated in articles 36(1) point (j) and 56 point (e) of CRR respectively). If an investment firm is not subject to any requirements derived from CRR and/or CRD, but is subject to any other national provisions of prudential nature, then it should report the equivalent own funds using the most appropriate breakdown method between the below types of capital. Please note that the amounts reported in this worksheet may differ from the own funds amounts calculated under the IFR/IFD as those are requested in worksheet “IF1”. Row Legal references and instructions 0010 Own funds Articles 4(1)(118) and 72 of CRR. The own funds of an institution shall consist of the sum of its Tier 1 capital and Tier 2 capital. COREP → C 01.00, row 010, column 010. 0020 Tier 1 capital
Article 25 of CRR.
The Tier 1 capital is the sum of Common Equity Tier 1 Capital and Additional Tier 1 capital. COREP → C 01.00, row 015, column 010. 0030 Common Equity Tier 1 capital
Article 50 of CRR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS COREP → C 01.00, row 020, column 010. 0040 ADDITIONAL TIER 1 CAPITAL
Article 61 of CRR.
COREP → C 01.00, row 530, column 010.
0050 TIER 2 CAPITAL
Article 71 of CRR.
COREP → C 01.00, row 750, column 010.
3.4.2 Own funds requirement
This panel summarizes the total risk exposures amounts as defined in Article 92(3) of the CRR. Investment firms that are only subject to initial capital requirements under the CRD should not fill this panel. If an investment firm is not subject to any EU requirements derived from CRR and/or CRD, but is subject to any other national provisions of prudential nature, then it should report the equivalent Pillar 1 own funds requirements. Please note that Pillar 1 own funds requirements should be reported in the form of total risk exposure amount (i.e. by multiply the Pillar 1 own funds requirements by 12.5). Row Legal references and instructions 0060 TOTAL RISK EXPOSURE AMOUNT Articles 92(3), 95, 96 and 98 of CRR. COREP → C 02.00, row 010, column 010.
3.4.3 Initial capital
This panel collects data on initial capital.
Row Legal references and instructions
0070 Initial capital
Article 28 to 32 of the CRD
Please select the minimum capital requested for authorisation from the drop￾down list:

• EUR 25 000
• EUR 50 000
• EUR 125 000
• EUR 730 000
• Other, if national legislation sets different amounts(please use row 0080
  to specify the amount)
  0080 If other, please specify amount (in the same reporting unit and currency as specified in ‘Input’ worksheet) If the firm selected “Other” in row 0070, please specify the amount in the same reporting unit and currency as selected in the “Input” worksheet.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS
3.5 IF 01.00 – Own funds composition (IF 1)
The “IF1” worksheet contains the compositions of the own funds that an investment firm holds under IFR/IFD: Common Equity Tier 1 capital (CET1), Additional Tier 1 capital (AT1) and Tier 2 capital (T2). The items in this worksheet should be reported gross of transitional adjustments. This means that the figures should be calculated in accordance with the final provisions (i.e. as if there were no transitional provisions). Row Legal references and instructions 0010 OWN FUNDS
Article 9 IFR.
The own funds of an investment firm shall consist of the sum of its Tier 1 capital and Tier 2 capital. The total sum of rows (0020, 0380) shall be reported. 0020 TIER 1 CAPITAL The Tier 1 capital is the sum of Common Equity Tier 1 Capital and Additional Tier 1 capital. 0030 COMMON EQUITY TIER 1 CAPITAL
Article 9 IFR.
Article 50 of CRR.
0280 ADDITIONAL TIER 1 CAPITAL
Article 9 IFR.
Article 61 CRR.
0380 TIER 2 CAPITAL
Article 9 IFR.
Article 71 CRR.
3.6 IF 02.00 – Own funds requirements (IF 2)
The “IF2” worksheet collects data on the own funds requirements under IFR/IFD. The items in thistemplate should be reported gross of transitional adjustments. This means that the figures should be calculated in accordance with the final provisions (i.e. as if there were no transitional provisions). Row Legal references and instructions 0010 Own fund requirement
Article 11(1) and (2) IFR.
Article 8 of the [Draft RTS on prudential consolidation under IFR]

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS For investment firms other than small and non-interconnected, the amount to be reported in this row shall be the maximum amount reported in rows 0020, 0030 and 0040. For small and non-interconnected investment firms this item shall be maximum of rows 0020, 0030. 0020 Permanent minimum capital requirement
Article 14 IFR.
Article 10 of the [Draft RTS on prudential consolidation under IFR]
0030 Fixed overhead requirement
Article 13 IFR.
Article 9 of the [Draft RTS on prudential consolidation under IFR]
0040 Total K-Factor Requirement
Article 15 IFR.
Article 11 [Draft RTS on prudential consolidation under IFR].
For small and non-interconnected investment firms, this data item is not relevant and should equal to zero or left blank.
3.7 IF 03.00 – Fixed overheads requirement calculation (IF 3)
The “IF3” worksheet collects information with regard to the calculation of the fixed overheads requirements under IFR/IFD. Investment firms should use the provisions prescribed in the IFR/IFD and the [Draft RTS on mandate of Article 13(4)] for calculating the fixed overheads requirements. The items in thistemplate should be reported gross of transitional adjustments. This means that the figures should be calculated in accordance with the final provisions (i.e. as if there were no transitional provisions).
3.7.1 Fixed Overheads Requirement calculation
Row Legal references and instructions
0010 Fixed Overhead Requirement
Article 13(1) IFR.
Article 9 of the [Draft RTS on prudential consolidation under IFR]
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 3 of the [Draft RTS on own funds requirements for investment firms based on fixed overheads under
Article 13(4) of IFR], the amount reported shall be the fixed overheads requirement
imposed by the competent authority in accordance with Article 13(2) IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS In the cases specified in Article 13(3) IFR, 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 1(1) and (2) of [Draft RTS on mandate of Article 13(4)].
Investment firms shall report the fixed overheads of the previous year after the distribution of profits. Row 0020 is the difference between rows 0030 and 0070. 0030 Total expenses of the previous year after the distribution of profits
Article 1(1) of [Draft RTS on mandate of Article 13(4)].
The amount to be reported shall be after the distribution of profits.
Row 0030 is the difference of rows 0050 and 0060. The amount reported shall be a positive amount. 0040 Of which: Fixed expenses incurred on behalf of the investment firms by third parties
Article 1(5) of [Draft RTS on mandate of Article 13(4)].
0050 Total expenses before distribution of profits The amount to be reported shall be before the distribution of profits. 0060 Distribution of profits Value of the profits distributed in the previous year. Row 0060 shall be lower than row 0050. 0070 Total deductions
Article 13(4) IFR.
Article 1(6) of [Draft RTS on mandate of Article 13(4)].
Sum of all amounts reported in rows (0080-0190).
0080 Staff bonuses and other remuneration
Point (a) of Article 13(4) IFR.
Article 1(4) of [Draft RTS on mandate of Article 13(4)].
0090 Employees', directors' and partners' shares in net profits Point (b) of Article 13(4) IFR.
Article 1(3) of [Draft RTS on mandate of Article 13(4)].
0100 Other discretionary payments of profits and variable remuneration Point (c) of Article 13(4) IFR. 0110 Shared commission and fees payable Point (d) of Article 13(4) IFR. 0120 Fees, brokerage and other charges paid to CCPs that are charged to customers Point (a) of Article 1(6) of [Draft RTS on mandate of Article 13(4)]. 0130 Fees to tied agents

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS Point (e) of Article 13(4) IFR. 0140 Interest paid to customers on client money where this is at the firm's discretion Point (b) of Article 1(6) of [Draft RTS on mandate of Article 13(4)]. This data item is not relevant for small and non-interconnected investment firms and should be equal to zero. 0150 Non-recurring expenses from non-ordinary activities Point (f) of Article 13(4) IFR. 0160 Expenditures from taxes Point (c) of Article 1(6) of [Draft RTS on mandate of Article 13(4)]. 0170 Losses from trading on own account in financial instruments Point (d) of Article 1(6) of [Draft RTS on mandate of Article 13(4)]. 0180 Contract based profit and loss transfer agreements Point (e) of Article 1(6) of [Draft RTS on mandate of Article 13(4)]. 0190 Expenditure on raw materials For commodity and emission allowance dealers:
Article 2 of [Draft RTS on mandate of Article 13(4)].
0200 Projected fixed overheads of the current year
Article 3 of [Draft RTS on mandate of Article 13(4)]
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 previous year: row 0020) – (Projected fixed overheads of the current year: row 0200))/ (Annual fixed overheads of the previous year: row 0020)].
3.8 IF 04.00 – Total K-factor requirement calculations (IF 4)
The “IF4” worksheet collects data on the K-factor requirements and the factor amount under IFR/IFD. When filling in this worksheet, investment firms should also refer to the [draft RTS S to specify the methods for measuring the K-factors (Article 15(5), point a) of the IFR)], [Draft RTS on the definition of segregated account (Article 15 (5) point b) of the IFR)], [Draft RTS to specify the calculation of the amount of the total margin for the calculation of K-CMG (Article 23(3) of the IFR)] and [Draft RTS to specify adjustments to the K-DTF coefficients]. For the purposes of this data collection only, investment firms that have been granted the permission to calculate net positions and own funds requirements on a consolidated basis in accordance with Article 325 of the CRR, shall assume that they will maintain this permission under the IFR when calculating K-NPR, K-TCD, and K-CON. The remaining investment firms shall assume that this permission will not be granted.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS The items in thistemplate should be reported gross of transitional adjustments. This means that the figures should be calculated in accordance with the final provisions (i.e. as if there were no transitional provisions). Please note that the worksheet shows all amounts as integers. In cells with a formula, this might cause some decimal numbers to appear as zero. The exact number will be taken into account when processing the data.
3.8.1 Total K-factor requirement calculations
Row Legal references and instructions
0010 TOTAL K-FACTOR REQUIREMENT
Article 15(1) IFR.
0020 Risk to client
Article 16 IFR.
The amount reported shall be the sum of rows (0030-0080).
0030 Assets under management
Article 15(2) and Article 17 IFR.
Point (c) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. Assets under management shall contain the discretionary portfolio management and non-discretionary advisory arrangements. 0040 Client money held - Segregated
Article 15(2) and Article 18 IFR.
Point (a) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0050 Client money held - Non - segregated
Article 15(2) and Article 18 IFR.
Point (a) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0060 Assets safeguarded and administered
Article 15(2) and Article 19 IFR.
Point (a) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0070 Client orders handled - Cash trades
Article 15(2) and Article 20(1) and point (a) of Article 20(2) IFR.
Point (a) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0080 Client orders handled - Derivatives Trades
Article 15(2) and Article 20(1) and point (b) of Article 20(2) IFR.
Point (a) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0090 Risk to market
Article 21(1) IFR.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS The amount reported shall be the sum of rows (0100-0110). 0100 K-Net positions risk requirement
Article 22 IFR.
Point (d) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0110 Clearing margin given
Article 23(2) IFR.
Point (e) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 0120 Risk to firm
Article 24 IFR.
The amount reported shall be the sum of rows (0130-0160).
0130 Trading counterparty default
Article 26 and Article 24 IFR.
Point (d) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. 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) IFR. In the event of stressed market conditions, in accordance with point (c) of Article 15(5) IFR, investment firms shall apply an adjusted coefficient as specified in point (a) of Article 1(1) of [Draft RTS to specify adjustments to the K-DTF coefficients]. Daily trading flow factor shall be calculated in accordance with point (a) of Article 33(2) IFR. Point (b) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR] 0150 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) IFR. In the event of stressed market conditions, in accordance with point (c) of Article 15(5) IFR, investment firms shall apply an adjusted coefficient as specified in point (b) of Article 1(1) of [Draft RTS to specify adjustments to the K-DTF coefficients]. Daily trading flow factor shall be calculated in accordance with point (b) of Article 33(2) IFR. Point (b) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR] 0160 K-Concentration risk requirement
Article 37(2), 39 and Article 24 IFR.
Point (f) of Article 11(3) of the [Draft RTS on prudential consolidation under IFR]. Columns Legal references and instructions 0010 Factor amount

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS 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 IFR.
3.9 Identified staff
The “Identified staff” worksheet collects information on the number of identified staff whose professional activities have a material impact on an investment firm's risk profile or assets it manages under the IFD. Under Article 30(4) of the IFD, the EBA, in cooperation with ESMA, is mandated to “develop draft regulatory technical standards to specify appropriate criteria to identify the categories of individuals whose professional activities have a material impact on the investment firm's risk profile as referred to in Article 30(1)”. The aim of this worksheet is to assess the impact of the application of this Draft RTS compared to the status quo. In this worksheet the investment firms should report the total number of staff, as well as the number of staff identified under different scenarios. The reporting unit in this worksheet should be units. Column Legal references and instructions 0010 Number of staff All employees and all members of their respective management bodies, or employees and members of their respective management bodies identified under each scenario. Row Legal references and instructions 0010 Total number of staff All employees and all members of their respective management bodies. The total number of staff should be indicated as headcount (the number of natural persons). 0020 Total number of identified staff under baseline scenario Total number of staff identified under criteria in paragraphs (1) to (15) of Article 3, and points (a) to (c) of Article 4 (1) of the RTS on identified staff under CRD. The baseline scenario is the current situation, i.e. the RTS on identified staff under CRD. 15 0030 Total number of identified staff under scenario A

15 Commission Delegated Regulation (EU) No 604/2014 of 4 March 2014 supplementing Directive 2013/36/EU of the European Parliament and of the Council with regard to regulatory technical standards with respect to qualitative and appropriate quantitative criteria to identify categories of staff whose professional activities have a material impact on an institution's risk profile.

EBA DATA COLLECTION EXERCISE FOR INVESTMENT FIRMS – TEMPLATE INSTRUCTIONS Total number of staff identified under criteria in paragraphs (1) to (9) of Article 5, and points (a) to (d) of Article 6 (1) of the RTS on identified staff (Article 30 (4) of the IFD). Scenario A is the scenario where the threshold for material business unit in
Article 5 (4) of the Draft RTS on identified staff (Article 30 (4) of the IFD) is
set equal or more than 10% of own funds requirements.
0040 Total number of identified staff under scenario B Total number of staff identified under criteria in paragraphs (1) to (9) of Article 5, and points (a) to (d) of Article 6 (1) of the RTS on identified staff (Article 30 (4) of the IFD). Scenario B is the scenario where the threshold for material business unit in
Article 5 (4) of the Draft RTS on identified staff (Article 30 (4) of the IFD) is
set equal or more than 20% of own funds requirements.