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

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NPL backstop

NPL backstop
We are critical of the filling of Template F39. Our Data warehouse does not have complete historical data on the NPE portfolios. Especially the long-term time-passed-ranges (> 7 years) are expected to cause problems, as NPE data were not implemented in accounting before 2013 and the information cannot be collected retrospectively.

We are also critical of the specifications for the requested disclosure „of which: Purchased or originated credit-impaired financial assets“ in Template F39.
Regulation 2019/630 Nr. 8 states: „NPEs purchased by an institution should therefore be subject to a calendar that starts to run from the date on which the NPE was originally classified as non-performing, and not from the date of its purchase. For that purpose, the seller should inform the buyer of the date of the classification of the exposure as non-performing.“
We see procedural problems concerning the exchange of information between seller and buyer. New processes would have to be implemented in the future. It is questionable whether a standardised, automated solution for the data exchange can be found. Manual processes would not be desirable, due to the fact that they are expensive, slowly and error-prone.
Furthermore, this information is not available for existing exposures.
Finally, it has to be assessed whether these data exchanges are in line with the German Datenschutzgrundverordnung (DSGVO).

FINREP

FINREP
Yes, we welcome the adjustment as it will keep our IFRS annual reporting in line with FINREP.

Additional question: According to the DPM 2.9 regulations, it is not possible to present impairments with a positive sign, as this is excluded by the EBA validation rules v5660_s and v5662_s. Is it correct that a disclosure of positive impairments is permitted for POCI in DPM 3.0 (see Appendix V 2.70 (d))? This amendment might have also effects on the accounting of POCIs in our IFRS annual reporting. Up to now an increase in the expected cash flows exceeding the carrying amount at initial recognition is shown via write-ups to the carrying amount and not via a positive impairment.
The instructions are clear.
The implementation is uncritical.
Since the Cash balances at central banks and other demand deposits are to be reported separately in some templates in DPM 3.0, it would be consistent from our point of view if they were generally no longer subsumed under the Loans and advances, but instead managed as a separate class (in addition to Debt securities and Loans and advances, among Debt instruments).

If the Cash balances at central banks and other demand deposits are shown separately in all impairment templates in DPM 3.0, an additional line for the Cash balances at central banks and other demand deposits should be inserted in Template F12.2.

We also recommend a separate disclosure of Cash balances at central banks and other demand deposits for Templates F16.1, F16.2, F30.2 and F31.1. At the moment, they are shown under Loans and advances. In our opinion, this disclosure is confusing because Loans and advances and Cash balances at central banks and other demand deposits are mixed.

For Template F5.1 we recommend the following addition for the heading:
5.1 Loans and advances other than held for trading and trading assets by product and cash balances at central banks and other demand deposits
Thus, it is clear that the Cash balances at central banks and other demand deposits are also included here.

In Annex V we recommend the following clarification:
Part 1.30: Financial assets shall be distributed among the following classes of instruments: 'Cash on hand', 'Cash balances at central banks and other demand deposits', 'Derivatives', 'Equity instruments', 'Debt securities' and 'Loans and advances'.

Part 1.33: In FINREP, ‘debt instruments’ shall include ’Cash balances at central banks and other demand deposits’, ‘loans and advances’ and ‘debt securities’.
-> see also Annex V Part 2.366.
The implementation is uncritical.
The implementation is uncritical.

Name of organisation

DZ BANK