Question ID
2017_3429
Legal act
Directive 2013/36/EU (CRD)
Topic
Supervisory reporting - Supervisory Benchmarking
Article
78
Paragraph
2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
Article/Paragraph
Templates C 102.00 and C 103.00 of Annex I
Type of submitter
Credit institution
Subject matter
Specialised Lending exposures
Question

Could you confirm that Specialised lending exposures should not be reported in templates C 102.00 or C 103.00?

Background on the question

The value ‘Corporate – Specialised lending’ was present in the Annex II instructions regarding the HDP perimeter of 2016 exercise for the template C 103.00.

However as this value did not appear in the ‘exposure class’ column of the template C 103.00 in Annex I the specialised lending was then not reported.

This value is no more quoted as one of the different ‘exposure class’ possible values in the Annex II regarding template C 103.00 or template C 102.00 for the RWA benchmarking 2018 exercise. Therefore it seems logical not to report the ‘Specialised lending’ exposures for the 2018 RWA benchmarking exercise, neither in template C 103.00 nor in template C 102.00.

For last year's exercise, the Specialised Lending exposures were not requested.

Submission date
Final answer

For the purposes of defining the corporate portfolios of template C 102.00 and C 103.00 of Annex I to the Draft ITS on benchmarking for the 2018 exercise (applicable for the reference date end-2017 data) (Draft ITS on Supervisory Benchmarking), the Draft ITS on Supervisory Benchmarking refers to the exposure class ‘corporates’ (C 102.00) respectively distinguishes between ‘corporates – SME’ and ‘corporates – No SME’ (C 103.00), i.e. it does not refer anymore to the (sub-)exposure classes defined for the purposes of templates C 08.01 / C 08.02 of Annex I to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting).

Therefore, and in accordance with Article 147 of Regulation (EU) No 575/2013 (CRR), the exposure class ‘corporates’ and its sub-exposure classes ‘corporates – SME’ and ‘corporates – No SME’ defined in the Draft ITS on Benchmarking include also specialised lending exposures, which are therefore in the scope of the benchmarking exercise 2018. The specialised lending exposures are to be reported in the respective templates according to the volume of the annual sales / total annual turnover of the counterparty.

 

Disclaimer

The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal. The text of the Implementing Regulation may differ from the text of the draft ITS to which this Q&A refers.

Status
Archive
Answer prepared by
Answer prepared by the EBA.
Note to Q&A

Update 26.03.2021: This Q&A has been archived in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking.