Could the meaning of the following statements included in point 2 of Part I of Annex II of the DR be clarified:
a. "a nominal cash short position may not be offset by an equivalent nominal long position taken in derivatives”?
b. “Delta-adjusted long positions in derivatives may not compensate identical nominal short positions taken in other financial instruments due to the delta adjustment”?

Can we include a long position in a UCITS fund in the calculation of the net short position? And if the position in the UCITS fund has to be included in the calculation, and taking into account that Article 3(3) of the Regulation specifies that “no person shall be required to obtain any real-time information as to such composition from any person”, is there a requirement to update its composition on a daily basis?

In calculating a net short position in sovereign debt for purposes of notification to the relevant competent authorities, it would seem that "single sovereign bond futures" need to be included. A number of sovereign debt futures contracts reference an underlying basket of securities. Would these futures be excluded from such calculations or is there an expectation that there is a need to look through to, say, the cheapest-to-deliver bond (see bund futures, for example)?

Under Article 3(3) of the Regulation and Annex II Part 1.3 & 2.4 of the DR, firms need only to look-through indices, baskets and ETFs to the extent that doing so is reasonable having regard to publicly available information. How should this condition be understood?

Article 8(3) of the DR states that “provided always that they are highly correlated in accordance with Article 3(5) of the Regulation and with paragraphs 4 and 5, all net holdings of sovereign debt of a sovereign issuer which is highly correlated with the pricing of the sovereign debt in any short position shall be included in the calculation of the long position”. Does the use of the language “shall be” imply that it is a mandatory requirement to net long positions in sovereign debt of one Member State which are “highly correlated” with a short position in another Member State?