Im pretty sure that any reported level 3s at the end of KS1, officially go down as secure level 3s. Something to do with their not officially being legal requirements for sub levels, so official data just goes on amount of L2s, amount of L3s etc. Do correct me if im wrong though! Maybe hence why they are asking for your 3c's to be officially assessed as 2a's - they dont see them as secure level 3s. Ive not come across it before, but its a possible expanation.