List of Q&As

FINREP: Counterparty classification of European institutions

This question ask for a clarification of the classification of European institutions into counterparty sectors for financial information templates (FINREP) foreseen by EBA FINAL draft implementing Technical Standards 2013-02, Anex V, Part 1. Counterparty breakdown across all templates shall align with ECB statistical requirements ECB/2008/32. In Regulation (EU) No 549/2013 of the European Parliament and of the council of 21 May 2013 on European system of national and regional accounts in the European Union, in paragraph 19.12. is stated that “The European Investment Bank and the European Investment fund are separate institutional units classified in the “Other financial intermediaries, except insurance corporations and pension funds” subsector (S.125) of the “financial corporations” sector (S.12)”. 1) Does FINREP follow this Regulation (EU) No 549/2013 in case of The European Investment Bank and the European Investment fund classification? 2) What counterparty sector for purpose of FINREP is the European Financial Stability Facility classified into? 3) Is there any list of European institutions including information about its counterparty sectors for purposes of FINREP available?

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: 2013_139| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 07/08/2013

FINREP: Definition of Credit institutions and Other financial corporations

This question asks for a clarification of the definition of Credit institutions (bank and multilateral banks) and Other financial corporations for financial information templates (FINREP) foreseen by EBA FINAL draft implementing Technical Standards 2013-02 published on 26 July 2013, Anex V, Part 1. Counterparty breakdown across all templates shall align with ECB statistical requirements ECB/2008/32. The Article 1 of that ECB regulation provide us with definition of MFI and breakdown of MFI to a) central banks, b) credit institutions as defined in Article 4(1) of Directive 2006/48/EC and c) other MFIs (e.g. Money market funds). For purpose of FINREP it is not clear if c) other MFIs (e.g. Money market funds) as defined in ECB Regulation shall be classified as Credit institutions sector (bank and multilateral banks) or Other financial corporations sector.

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: 2013_137| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 07/08/2013

Large exposures: LE4 and LE5 on maturity buckets for institution's and unregulated entities applies to firms reporting on solo basis.

Do COREP templates LE4 and LE5, which contains the maturity structure of 10 largest exposures to unregulated financial entities apply to an entity reporting on solo basis?

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: 2013_133| Topic: Supervisory reporting - Large Exposures| Date of submission: 07/08/2013

Large exposures: Definitions of ‘institutions’ for the purpose of the LE reporting

‘Investment funds’ is not a defined term within Article 4 of Regulation (EU) No 575/2013.

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: 2013_131| Topic: Supervisory reporting - Large Exposures| Date of submission: 07/08/2013

FINREP - template F14 changes for the period

Are changes relevant "for the period" to be reported year-to-date (YTD) or only of the last quarter?

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: 2013_126| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

FINREP Loan commitments, financial guarantees and other commitments received

How shall off-balance sheet exposures be reported in first FINREP reports if the data is not available in the accounting systems? Can a starting date for collecting this dta be set?

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: 2013_125| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

FINREP - template F. Loans and advances by product, by collateral and by subordination

How shall breakdown of loans according to product, collateral and subordination be reported if collateral information is not available to together with product?

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: 2013_124| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

FINREP - template F7 Accumulated write-offs

How shall accumulated write-offs be reported in the first reporting reference dates when all data may not be available?

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: 2013_123| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

FINREP Past due but not impaired < 30 days

Can materiality thresholds be applied when reporting "technical" past due exposures?

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: 2013_122| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

FINREP Amount of cumulative changes in fair value due to credit risk

In the absence of accurate information how the amount of cumulative changes in fair value due to credit risk should be reported? This question is also relevant for templates F4.2, F8.1, F16.5, F45.1.

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: 2013_121| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

FINREP, interim dividends

What amount should be reported on row 260 of template F1.3, the dividends distributed during the year or the proposed dividends for the financial year?

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: 2013_120| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 06/08/2013

IP Losses: Direct and Indirect costs associated with immovable property losses

In relation to direct and indirect costs associated with immovable property losses can the EBA please confirm what costs should be included?

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: 2013_116| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 02/08/2013

FINREP: thresholds applicable to F20.1 - 20.7 (geographical breakdown)

How to interprete the threshold for FINREP templates 20.1 till 20.7: - link in article 5a(4) to COREP table 4 seems not correct; - is the threshold domestic/non domestic applicable for all templates 20.x? - if the threshold is per table: what with annexes 20.4 - 20.7? is the threshold applicable per country of the counterparty?

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: 2013_113| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/08/2013

COREP: CA5.1 Template (Rows 133, 136 and 138)

With the addition of Rows 133, 136 and 138 into the CA 5.1 template we seek clarification on whether or not these are sub-sets of other Rows, or standalone.

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: 2013_112| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 01/08/2013

FINREP - reporting by residence of the counterparty - format of the country code

In which format does the ISO country code (FINREP tables 6, 20.4, 20.5, 20.6, 20.7) need to be reported: Alpha-2 (eg.: BE), Alpha -3 (eg.: BEL) or three-digit numeric (eg.: 056)?

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: 2013_108| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/08/2013

COREP: CR GB 3 Template

Can the EBA please confirm if there is a threshold below which this template does not require to be completed? Our non-domestic % is circa 0.8% and covers circa 100 countries.

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: 2013_107| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 31/07/2013

Liquidity: First submission date for Stable Funding template

EBA-ITS-2013-02 Article 18 (7) states: "for the period from 31 March 2014 to 31 December 2014 as a deviation from point (a) of Article 3 (1) the reporting remittance date relating to monthly reporting shall be the 30th calendar day after the reporting reference date". This would mean that the first submission of the LCR template should be by 30 April 2014, but we question whether this should also apply for the first submission of the SFR template? As things stand, it would appear that the first submission of the SFR template should be in line with Article 18 (6).

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: 2013_106| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 31/07/2013

COREP: Validation rules on draft ITS for C19.00 (MKR SA SEC)

In this return (C 19.00 MKR SA SEC) we are asked to complete the average risk weight (%) for securitisations going through the supervisory formula approach and the internal assessment approach, in columns 260, 290, 490 and 520. The validation rules in Annex XV specify that these % figures are simply added together, as for any other columns on the return. This produces a mathematically nonsensical result. For example, for the total row (row 010) we should add together the average % amounts from each securitisation category, to reach a total average %. The total is thus the sum of the average %s of each row, a figure that owes more to how many rows are being completed than to any particular value. % Would it not be more mathematically sensible to take the average % of the total? In other words, to replace the existing {r010,c260} = {r030,c260} + {r060,c260} + {r090,c260} with {r010,c260} = {{r030,c260} * {r030,c250}} + {{r060,c260} * {r060,c250}} + {{r090,c260} * {r090,c250}} ? Or if this is not suitable, to not calculate the value at all?

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: 2013_102| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 29/07/2013

FINREP - Contents of template 41.2 Use of the fair value - Crossing col 030 "Hybrid contracts" / Row 020 "equity instruments"

FINREP Template 41.2 Use of the fair value - Crossing col 030 "Hybrid contracts" / Row 020 "equity instruments" : this crossing is forbidden ; even if few cases are expected, how do we have to report possible occurrences ?

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: 2013_97| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 26/07/2013

FINREP - Contents of template 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount"

FINREP - Template 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount" : for entities with a different accounting treatment under IFRS Group scope and under CRR Group scope, the amount related to which scope is expected ?

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: 2013_96| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 26/07/2013