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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?

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| 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?

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| 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.

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| 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?

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| 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?

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| 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?

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| 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.

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| 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)?

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| 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.

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| 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).

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| 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?

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| 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 ?

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| 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 ?

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| Date of submission: 26/07/2013

FINREP - Contents of template 40.1 Group structure "entity-by-entity" - Col 080 "Profit or (-) loss of investee"

FINREP - Template 40.1 Group structure "entity-by-entity" - Col 080 "Profit or (-) loss of investee" : which result is expected in column 080 : "profit or loss for the period" or "total comprehensive income for the period" ?

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

ID: 2013_95| Topic: Supervisory reporting| Date of submission: 26/07/2013

FINREP - Contents of template 40.2 Group structure "instrument-by-instrument"

FINREP - Contents of template 40.2 Group structure "instrument-by-instrument" : we don't understand the scope of templates 40.2 : do we have to report all securities in our portfolio issued by an entity included in our accounting scope ? The amounts expected in columns 030 to 050 (holding company) are related to the security or to the holding company ? We need further explanations"

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

ID: 2013_93| Topic: Supervisory reporting| Date of submission: 26/07/2013

FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope

FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope : we understand that the scope to be considered for the templates 40.1 and 40.2 is the Accounting Group (including insurance companies for example) and not the CRR Group (excluding insurance company for example). Can you confirm this point ?

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

ID: 2013_92| Topic: Supervisory reporting| Date of submission: 26/07/2013

FINREP - Contents of template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" et Column 050 "other related parties"

FINREP - Template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" and Column 050 "other related parties" : can you confirm that the column 020 "subsidiaries" includes transactions with "sister entities" ?

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

ID: 2013_91| Topic: Supervisory reporting| Date of submission: 26/07/2013

FINREP - Contents of template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]"

FINREP - Template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]" : for this row, the ITS refers to "products issued by entities outside the Group" -> Which level of Group has to be considered : Accounting Group (including insurance companies for example) or CRR Group (excluding insurance companies for example) ?

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

ID: 2013_90| Topic: Supervisory reporting| Date of submission: 26/07/2013

FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts"

FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts" : does the row 170 "liabilities under insurance and reinsurance contracts" include insurance company technical reserves?

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

ID: 2013_89| Topic: Supervisory reporting| Date of submission: 26/07/2013

FINREP - Contents of template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets"

FINREP - Template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets" : on which row do we have to set amounts linked to "other non financial assets" and reported on row 570 "other" in template 2 ?

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

ID: 2013_88| Topic: Supervisory reporting| Date of submission: 26/07/2013