Response to consultation on supervisory reporting changes related to CRR2 and Backstop Regulation (Framework 3.0)

Question 10: Are the instructions and templates clear to the respondents? C 07.00 rows 330 and 340: In our opinion it may lead to certain difficulties to include deducted items in the credit risk template. Could you please give guidance on which exposures shall be included in these positions. It is especially unclear, whether deductions according to Art. 36, Art. 56, Art. 66 and Art 72e CRR such as losses for the current financial year, deferred tax assets, deductions in relation with the prudential backstop, etc. shall be included in C 07.00 rows 330 and 340 and which exposure class shall be used.

Question 16: Are the instructions and templates clear to the respondents? C 34.08 rows 0070 and 0080: In our opinion the criteria which shall be used to distinguish “Investment grade” and “Non-investment grade” are not sufficiently clear. The instructions do not offer any guidance on this subject. Would you be so kind to add a definition/ a reference to a definition to the instructions regarding rows 0070 and 0080 of template C 34.08. Should the external rating be used as a guidance and which criteria shall be followed if no external rating is available?