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Precisions on the Entity Code on COREP Solva Group (C06.02) and FINREP F40.01

Is the EBA expecting a specific relation between the column 020 in the COREP C06.02 and the column 020 of the FINREP F40.01 template ? The annexes 2 (solvency) and 5 (FINREP) of the regulation 680/2014 do not bring any information regarding an expected accordance, and only indicate that the code should be unique for each line of the template. However, those codes seem to have the same purpose, and the same entities are likely to be reported on those templates on each remittance. Therefore : - Is an entity reported in both C06.02 and F40.01 supposed to share the same code on the columns 020 of the both templates? - Is an entity reported in one of those templates supposed to share the same code in the next remittance of the template? Similar questions can be asked regarding the columns 010 of the large exposures templates (C27 to C31).

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3390| Topic: Supervisory reporting| Date of submission: 12/07/2017

Reserves of Equity Accounted Entities

How should dividends received by the reporting entity from an equity accounted entity be classified in the equity rows of Template 1.3 and Template 17.3 ?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3374| Topic: Supervisory reporting| Date of submission: 29/06/2017

“Past due” columns: How to count number of days for “1 year” and “5 years” past due?

In Template F 18.00 the “cross carrying amount / nominal amount” and the “accumulated impairment, accumulated negative changes in fair value due to credit risk and provisions of non-performing exposures” have to be allocated to different “past-due” columns according to its number of days past due. How many days past due have to be assumed in order to allocate an exposure to past-due column “1 year” or “5 years” respectively?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3301| Topic: Supervisory reporting| Date of submission: 24/05/2017

Template F 31.00 Related parties column 010 and column 020.

How should be performed the split between column 010– “Parent and entities with joint control or significant influence”- and column 20 “Subsidiaries and other entities of the same group”? In column 010 – “Parent and entities with joint control or significant influence”, should be reported only the balances with our Head Office or also should be included the upper hierarchy level of our shareholder and their related group entities? In column 020 – “Subsidiaries and other entities of the same group”, should be reported only our affiliates or also should be included the upper hierarchy level of our shareholders and their related group entities?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_3032| Topic: Supervisory reporting| Date of submission: 05/12/2016

Transferred financial assets Template 15

Should in F15 template that collateral obtained from reverse repurchase agreement (assets) be reported that is given as collateral in a repurchase agreement (liability)?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_2926| Topic: Supervisory reporting| Date of submission: 04/10/2016

FINREP -contents of template F40.01 Group Structure

During the last reporting of 31/12/2015 we received a return from ACPR about the way of filling this template (Fin. 40.1), we are coming back to you because we need additional information to correct if necessary our last statement 31/12/2015.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_2820| Topic: Supervisory reporting| Date of submission: 06/07/2016

Counterparty breakdown by sector – definition of other financial corporations and non financial corporations

Article 35 in Annex V of Finrep defines 'other financial corporations' as all financial corporations and quasi-corporations other than credit institutions such as investment firms, investment funds, insurance companies, pension funds, collective investment undertakings, and clearing houses as well as remaining financial intermediaries and financial auxiliaries; ‘Non-financial corporations’ are corporations and quasi-corporations not engaged in financial intermediation but principally in the production of market goods and non-financial services according to the ECB BSI Regulation. Subsidiaries set up within non – financial group to issue debt instruments or to perform liquidity management activities within the group should be considered as ‘other financial corporations’ or ‘Non-financial corporations’?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_2793| Topic: Supervisory reporting| Date of submission: 16/06/2016

Counterparty Zuordnung Abwicklungsanstalten

Für FinRep sind in verschiedenen Tabellen Aufgliederungen nach sog. Counterparties erforderlich. In der Praxis stellt sich häufig die Frage, in welchen Sektor Abwicklungsanstalten einzuordnen sind. Hierunter fallen in der Praxis regelmäßig gehaltene Positionen ggü. der Heta Asset Resolution AG, der Erste Abwicklungsanstalt (EAA) sowie der FMW-Wertmanagement. Auf Basis der Counterparty-Definition in Annex V (1.35) ist in der Praxis ein eindeutige Zuordnung nur schwer möglich. Insofern stellt sich die Frage nach einer aus Sicht der Aufsicht korrekten Zuordnung von gehaltenen Positionen gegenüber den o.g. Gesellschaften. For Financial Reporting, breakdowns by ‘counterparties’ are required in various tables. In practice, this frequently gives rise to the question of which sector should be used for deconsolidated environments. This includes, in practice, positions regularly held in respect of Heta Asset Resolution AG, Erste Abwicklungsanstalt (EAA) and FMS Wertmanagement. On the basis of the counterparty definition in Annex V (1.35), a clear classification is difficult in practice. In this respect, there is a need to correctly (from a supervisory perspective) classify positions held in respect of the above-mentioned companies.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_2789| Topic: Supervisory reporting| Date of submission: 15/06/2016

Definition of mortgage loan and its collateral in FINREP template 13 (F13.01)

1. What kind of loans should be reported as “Mortgage Loans” for the purposes of FINREP template F13.01? 2. What kind of commercial and residential property should be reported as collateral for “Mortgage Loans” for the purposes of template F13.01?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_2754| Topic: Supervisory reporting| Date of submission: 27/05/2016

FINREP table 1.1 vs 20.4 – “cash and cash balances at central bank” and “other demand deposits”

Should “cash and cash balances at central bank” and “Other demand deposits” be included in FINREP table 20.4?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2016_2678| Topic: Supervisory reporting| Date of submission: 17/03/2016

FINREP Group Structure Template 40.02

For entities which are consolidated as part of the Group, but where we do not have any legal ownership over these entities, what should be included as the Holding Company on FINREP template 40.02?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2016_2670| Topic: Supervisory reporting| Date of submission: 10/03/2016

Trades receivables towards Central Banks

Could you clarify why in the FIN 5 template, it is not possible to put an amount in the cell « Trades receivables towards Central Banks” (Row 30 Column 10)?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2546| Topic: Supervisory reporting| Date of submission: 31/12/2015

Allocating transfer from Share Premiun to Other components of equity.

As per the cell { r160, c020} is greyed in F 46.00 template, transfers from share premiun to other items of equity and other increases or decreases are not possible to be reported. On the other hand, the cell {r100, c020} should be used to reclassify "Share Premiun" to "Other reserves" but, this line is not a correct source of equity change, since it is not a reduction of capital but a share premiun. Where or how transfers from share premiun to other reservers must be reported?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2492| Topic: Supervisory reporting| Date of submission: 30/11/2015

Forbearance – past term interest only mortgages

Should interest only mortgage exposures where the customer has not repaid the capital at term but continues to pay interest and is not considered to be in financial difficulty, ever be considered as forborne?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2474| Topic: Supervisory reporting| Date of submission: 19/11/2015

FINREP – Forborne Exposures

Is the definition of concession referred in paragraph 164 to be read as including all non-payment related concessions?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2450| Topic: Supervisory reporting| Date of submission: 28/10/2015

Exit criteria from non-performing forborne category

According to paragraph 157 of Annex V, a condition to exit the non-performing forborne category is that a period of (at least) one year has passed since the forbearance measures were applied (“cure period”). During this period, there must not be any past-due amount or concern regarding the full repayment of the exposure according to the post-forbearance conditions. If an amount due is unpaid during the “cure period”, the latter shall be considered as “discontinued” or “suspended”? In the former case, the counting of the year should restart from the date of any repayment; while in the latter case, the counting of the year shall continue since the date of any repayment.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2429| Topic: Supervisory reporting| Date of submission: 20/10/2015

Exit Criteria NPE

With regards to the EBA Implementing Technical Standard and specifically to the NPE exit criteria we would like to ask for your advice on how to handle the following case: Customer A is a performing exposure. Account 3 presents 91 dpd and as a result the whole customer is classified as NPE. Account 1 and 2 are classified as such due to contagion. Customer A - Performing exposure Account Balance % on total Days past due NPE Account 1 50 5% 0 50 Account 2 100 10% 0 100 Account 3 850 85% 91 850 1.000 100% 1.000 On the other hand Customer A is now a non performing exposure. It presents arrears over 90 dpd in an immaterial account i.e. account which is < 20% of the total customer balances. Customer A - Non performing exposure Account Balance % on total Days past due Performing - 1st option Performing - 2nd option Account 1 50 5% 91 0 0 Account 2 100 10% 0 0 100 Account 3 850 85% 0 0 850 1.000 100% 0 950 The question is should we upgrade Accounts 2 and 3 into performing, leaving Account 1 as an NPE or the whole exposure retated to the customer must remain as NPE? Please always assume that the customer is not impaired and no concerns regarding the full repayment of the debt exists. Based on paragraph 156 of the EBA ITS, the first option is valid, however this is not in line with the NPE entry criteria. In our opinion the second option is the correct one.  

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2378| Topic: Supervisory reporting| Date of submission: 07/10/2015

Retained Earnings in COREP/FINREP

I kindly require some clarification regarding the Retained Earnings amount which should be reported in F01.03 r190, c010. From my understanding and as per validation rule v3467_i, {F 01.03, r190 , c010}=={F 46.00, r210 , c060}, the Retained Earnings figure which should be reported in F 01.03 should not include Profit or Loss Attributable to Owners of the Parent (eligible and non-eligible profit or loss for the year) as the latter is to be reported in F 01.03 r250, c010. Conversely, Retained Earnings reported in COREP C 01.00 r130, c010, contains Previous Years Retained Earnings (r140) and Profit or Loss Attributable to Owners of the Parent (r160). In this regard, could you please confirm, or otherwise, that F 01.03 r190, c010 should not be equal to C 01.00 r130, c010? Kindly note that no guidance is provided in the EBA FINREP instructions.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2015_2300| Topic: Supervisory reporting| Date of submission: 15/09/2015

FinRep Table 2: Interest income & Expense: Derivatives – Hedge accounting, interest rate risk

How should interest income & interest expense on derivatives (hedge accounting) be presented in Table 2 ? (i) Linked basis: Reported in Interest Income (row 070) if the derivative is hedging an asset item and Reported in Interest Expense (row 130) if the derivative is hedging a liablity item OR (ii) Gross basis: Hedge accounting derivatives resulting in Interest Income should be reported in row 070 and hedge accounting derivatives resulting in Interest Expense should be reported in row 130.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2284| Topic: Supervisory reporting| Date of submission: 09/09/2015

defining a concession

Our questions refers to the border case, where a bank modifies terms and conditions in favour of a debtor who is in financial difficulties, but where - at the same time - the new terms and conditions are still less favourable or equal to the standard terms and conditions of the bank for comparable debtors. The matter might become clearer through a specific example: A debtor of a performing loan is in financial difficulties (let's say 25 days past due). Due to the existing financial problems the bank reduces the interest rate to a rate which is still above the standard interest rate for debtors with a similar risk profile of the bank. The bank has no doubt about the debtor being able to pay it's debt. Is this measure to be considered a forborne measurement? Paragraph 163 lays down, that forbearance measures consist of concessions towards a debtor that is experiencing or about to experience difficulties in meeting its financial commitments (“financial difficulties”), i.e. it states two conditions for a forbearance: a) a concession has taken place b) the concession refers to a debtor in financial difficulties There is no doubt, that the debtor in the above mentioned example is in financial difficulties, but is the above stated measure also a concession? paragraph 165 says: 165. Evidence of a concession includes the following: (a) a difference in favour of the debtor between the modified terms of the contract and the previous terms of the contract; (b) inclusion in a modified contract of more favourable terms than other debtors with a similar risk profile could have obtained from the same institution at that time. Our example meets only condition a) not condition b). This may lead to the conclusion that it is not a concession and therefore the above stated case does not refer to a forbearance measure. Paragraph 164 on the other hand lays down "...that would not have been granted had the debtor not been experiencing financial difficulties". If we view this statement individually, we may come to the conclusion that a concession has taken place; on the other hand it is somewhat contradictory to 163 and 165, from where one may deduct that a concession is a separately defined component of a forbearance measure. If we interpret this statement in the light of paragraph 165 b), i.e. that terms and conditions should not be more favourable than those applied to other comparable debtors the measure may not be a forbearance measure.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2231| Topic: Supervisory reporting| Date of submission: 19/08/2015

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