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FINREP: Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net

During the last update on the ITS Annex III in July 2013 the FINREP P&L template was modified by removing the line item for "Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net" (table 2 row 320 ITSoR March 2013) without any explanation. But in comparison with the published DPM in July 2013 which still contains the line item there is an inconsistency. In our opinion the line item is required to reach a consistent and meaningful P&L Statement, so that we assume that removing the line item is a mistake in the templates. If it is not an error it is necessary to give guidance on the disclosure of gains or losses on derecognition of investments in subsidiaries, joint ventures and associates.

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

ID: 2013_178| Topic: Supervisory reporting| Date of submission: 22/08/2013

COREP C25.00 (CVA): rows 030 and 040 for column 110 shouldn't be reported

in CVA report, the column 110 is requested for all methods but when we check the definition of this column "number of counterparties where the credit spread was determined using a proxy instead of directly observed market data". This definition suits more for CVA advanced method but no for standard method nor for based OEM, our question is the proxy used to determine credit spread is it really requested for standard method or OEM?

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

ID: 2013_171| Topic: Supervisory reporting| Date of submission: 19/08/2013

FINREP validation rules - references to missing rows

In the Validation Formulae (Appendix XV), there are many rows referred to that do not exist in the template (Appendix III). For example, in table 1.1 it is referred to rows 091, 092, 093, 094, 095, 171, 172, 173, 174, 175, 176, 177, 178, 231, 232, 233, 234, 235, 236 and 237, which do not exist in the template. There are many other similar examples. How should we interpret/handle these validation rules?

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

ID: 2013_165| Topic: Supervisory reporting| Date of submission: 16/08/2013

FINREP Template F 06.00 - reporting by country

Template 6 - Breakdown of loans and advances to non-financial corporations by NACE codes and by residence of the counterparty. Should this table be delivered per country?

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

ID: 2013_161| Topic: Supervisory reporting| Date of submission: 14/08/2013

FINREP: Calculation of accumulated changes in fair values- first application

Is it possible to apply a starting date for calculation of accumulated changes in fair values?

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

ID: 2013_158| Topic: Supervisory reporting| Date of submission: 14/08/2013

FINREP - Company only IFRS reporting

Please confirm the reporting requirements for a broker dealer reporting stand-alone company accounts under IFRS. Current reading of the guidance suggests that such an entity would be out of scope.

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

ID: 2013_153| Topic: Supervisory reporting| Date of submission: 12/08/2013

Validation Rules - Mistakes in the Annex XV

- In the validation rules file, a confusion is made between rows and columns in excel columns 'H' and 'I'. - The validation rule for row item 330 of the FINREP template F 01.01 is missing

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

ID: 2013_152| Topic: Supervisory reporting| Date of submission: 12/08/2013

Liquidity: Instructions on reporting outflows in relation to custody, clearing and cash managment

Are the references to the Basel rules correct? Looking at the January 2013 Basel document, paragrapphs 75 and 76 referred to in the instructions do not appear to be the relevant in this context, as they refer to stable retail deposits.

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

ID: 2013_150| Topic: Supervisory reporting| Date of submission: 09/08/2013

FINREP Reporting for firms with Accounting Reference Date other than 31 December

Article 18 (3) confirms that FINREP applies from 1 July 2014. We have a financial year end of 30 September which means that where we will report our first quarter's data for relevant templates (in full) as at 30 September 2014. For semi-annual templates should we only report a quarter's data in our first submission (1 July to end September) or should we start collecting data from 1 October, and report a full 6 months of data as at 31 March 2015? For annual templates should we only report a quarter's data in our first submission (1 July to end September) or should we start collecting data from 1 October, and report a full year's data as at 31 March 2015? The period 1 July 2014 to 30 September 2014 is a full quarter, so this will allow us to report a full quarter's data.

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

ID: 2013_147| Topic: Supervisory reporting| Date of submission: 09/08/2013

COREP CA1: Reference to CRR Art 3 is unclear

CA1 Row 524 Column 010 relates to Article 3 of CRR. Article 3 of CRR, relating to Application of stricter requirements by institutions states: "This Regulation shall not prevent institutions from holding own funds and their components in excess of, or applying measures that are stricter than those required by this Regulation. Can the EBA please confirm if this relates to the difference between Capital Requirement and Capital Holdings? Alternatively is this cell intended to reflect any additional capital holding dictated by competent authorities?

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

ID: 2013_146| Topic: Supervisory reporting| Date of submission: 09/08/2013

Leverage ratio: Exposure value of derivatives

Article 429.6 of Regulation (EU) No 575/2013 (CRR) states that the exposure value of financial derivatives listed in Annex II and of credit derivatives shall be calculated in accordance with the Mark-to-Market method (see Art. 274 of CRR). Based on such instructions, it is not clear if the above mentioned method shall be applied both to OTC and exchange trade derivatives, also including those contracts cleared with CCPs.

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

ID: 2013_145| Topic: Supervisory reporting| Date of submission: 09/08/2013

COREP: 'residence of the obligor' for the purposes of the CRGB1 template for supranational organisations and multilateral development banks

The guidelines for the CR GB 1 COREP template, Geographical breakdown of exposures by residence of the obligor, state that 'residence of the obligor' refers to the country of incorporation. However, how is this guideline to be applied in the case of exposures to either supranational organisations such as the EU (European Union) or multilateral development banks such as the EIB (European Investment Bank)?

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

ID: 2013_143| Topic: Supervisory reporting| Date of submission: 08/08/2013

Remittance dates in case of an accounting year-end which deviates from the calendar year

Is our understanding that submission of "financial information" based on their accounting year-end which deviates from the calendar year is relevant to FINREP templates only, but not to wider financial and prudential information (incl. COREP, LE, LR, LCR...) as well, correct?

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

ID: 2013_142| Topic: Supervisory reporting| Date of submission: 08/08/2013

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?

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| 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.

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| 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?

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| 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.

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| 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?

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| 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?

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| 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?

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| Date of submission: 06/08/2013