Austrian Federal Economic Chamber, Division Bank and Insurance
Referring to „Annex XIX instructions“ we want to emphasize the following issue:
As we have already highlighted at several occassions, point 5 in chapter 1.2. Concentration of funding by counterparty (C 67.00) should be seriously questioned.
„5. The totals of section 1 and section 2 shall equal an institution’s total funding as per its balance sheet reported under the financial reporting framework (FINREP).“
This because of the following:
The FINREP report has to be provided until one and a half months after the first reporting date, but the ALMM report is to be made already until the 15th of the following month to the reporting date. A harmonisation of the values in the ALMM report and the FINREP report is therefore only to a limited extent possible.
The FINREP report is a quarterly report, the ALMM report a monthly. Inbetween the quarter dates there can not be a harmonisation to FINREP.
In FINREP only the group is reported, the uncosolidated report of the ALMM has no reference to FINREP.
Clarification has been promised in the course of the ALMM review. Nonetheless the questioned passus is still nearly unchanged included in the document.
In this respect there has been published an EBA Q&A, but the answer does not refer to this topic (see also http://www.eba.europa.eu/single-rule-book-qa/-/qna/view/publicId/2015_2365).