List of Q&As

Row asset-backed securities in Asset encumbrance templates

Can you please make the row 060 'asset-backed securities' in table F 32.01 consistent with the Annex XVII (reporting on asset encumbrance) page 10 'of which: securitisations'? Same applies to row 180 in F 32.02.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2015_1999| Topic: Supervisory reporting - Asset Encumbrance| Date of submission: 09/05/2015

Realization of developers' collaterals and re-classification of developers into performing status

Clarifications are requested surrounding the classification of a borrower into default status and therefore into non-performing status, when the borrower is a developer / construction company and hence relies on the realisation of collaterals to repay his loans.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2018_3747| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 05/03/2018

Reporting of the interest income and interest expense from hedging derivatives

Our question is in which item of template F 02.00 (FINREP IFRS 9) interest income and interest expense from hedging derivatives classified in the category ”hedge accounting” should be reported, where: the hedging derivatives are used to hedge interest rate risk and are measured at fair value through profit or loss; the dirty price approach is the convention applied by the credit institution; and the hedged instrument is not measured at fair value through profit or loss (i.e. the hedged instrument is a debt financial instrument whose interest is recognized as “interest income” or “interest expense” in the statement of profit or loss).

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3601| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 23/11/2017

Template F 16.04 line row 070 – relevance for nGAAP

In Annex IV (Financial Reporting for National GAAP based on BAD) of Commission Implementing Regulation (EU) No 680/214 in template F 16.04 excel the row line 070 ”Gains or losses on Financial assets and liabilities held for trading” is not black, while this cell is an IFRS cell. Is it an error?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3578| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 31/10/2017

Reporting of transfer between capital surplus (share premium) and retained earnings in FINREP F 46 template.

Under the Hungarian legislation negative balance of retained earnings could be offset by a transfer from other elements of own funds. If such transaction occurs how should it be reported in template F46?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3504| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 31/08/2017

FINREP Template F20.04 (r210,r230)

Template F 20.04, row 210 reports ”Non-financial corporations – Of which: Loans collateralized by commercial immovable property”. However, in Hong Kong there could be non-financial corporations (NFC) borrowing loans that are collateralized solely by ”Residential immovable property” rather than by “Commercial immovable property”. For this case, should the corresponding loan amount be reported in row 230? Similarly, should household (HH) borrowing loans that are collateralized solely by ”Commercial immovable property” require to be reported in row 230, “Households – Of which: Loans collateralized by residential immovable property”?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3486| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 23/08/2017

Reporting of securitisation instruments in FINREP templates F 04.01 – F 04.04

How should Residential Mortgage-Backed Security (RMBS) instruments be reported in FINREP templates F 04.01 – F 04.04? Which counterparty sector should the RMBS be assigned to?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3477| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 17/08/2017

Definition of "hybrid contracts" in FINREP template F 08.01

What shall be considered a ‘hybrid contract’ for the purposes of reporting FINREP template F 08.01?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3476| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 17/08/2017

Promise to pay and financial difficulties

If a customer misses a payment he or she can promise to pay the amount due in the same month (after we have contacted our customer). Should we define such a situation as a promise to pay or as a payment reminder? We have currently defined this situation as a promise to pay (‘Toezegging’ in Dutch), but that may diverge from the EBA perception of the associated risk with a promise to pay. As there have been several discussions on this topic with our supervisor we would appreciate EBA guidance. This should provide us with sufficient information to define this event in such a way that there can be no misinterpretations about meeting forbearance criteria.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3463| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 11/08/2017

Disclosure of the difference between the fair value of a loan portfolio acquired/originated by a Bank and its contractual value

The fair value of a loan portfolio acquired/originated by a Bank differs from its contractual value. This difference (fair value adjustment on initial recognition (the “adjustment”)) has to be recognised in accordance with IFRS 3. In such case and since there is no separate column for this component, shall we reflect this adjustment in Template 4.4 row 170 ‘Loans and advances’ - under gross carrying amount (c010-c020) or under stock of provision (c030-c050)? We note that the issue of reporting this adjustment also arises on several templates which have no separate column for this component, namely F6, F7, F12, F20.4, F20.7, F18 and F19.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3431| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 02/08/2017

Reporting of assets credit-impaired at purchase within template F 04.03.1 and F 04.04.1

How shall row 190 (columns 015-070) within template 4.3.1 be filled in order to fully comply with, in our interpretation, contradictory attributes stated in the terms of both rows and columns?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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

ID: 2017_3410| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 20/07/2017

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).

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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 ?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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)?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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’?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| 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?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

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 - FINREP (incl. FB&NPE)| Date of submission: 27/05/2016