Question ID:
2015_2056
Legal Act:
Regulation (EU) No 575/2013 (CRR) as amended
Topic:
Supervisory reporting - FINREP (incl. FB&NPE)
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph:
Part 2, Annex V, Art. 180 - F19.00, c050
Disclose name of institution / entity:
No
Type of submitter:
Consultancy firm
Subject Matter:
FINREP Template 19 - column 050 - of which: Performing forborne exposures under probation
Question:

Due to the amended wording, it is unclear, whether only performing forborne exposures under probation which have been reclassified out of the non-performing forborne exposures category shall be reported in column 050 or all performing forborne exposures under probation which have been reclassified out of non-performing category at any time in the past. Regarding the two examples given below, the question is if both exposures have to be reported in column 050 of template F 19.00 or only exposure A? Exposure A was classified as non-performing with forbearance measure and fulfilled all required exit criteria mentioned in paragraph 157. Thus, exposure A was reclassified out of the non-performing forborne exposures category and has to be reported in column 050 as long as it does not fulfil the exit criteria of paragraph 176. Exposure B was classified as non-performing 2 years ago, no forbearance measure was granted. One year ago, exposure B fulfilled all exit criteria of paragraph 156 and was reclassified as performing. Six month ago, on exposure B an forbearance measure was applied which has not led the exposure to be classified as non-performing. Does exposure B have to be reported in column 050 of template F 19.00 due to the fact it was reclassified out of the non-performing category (without forbearance measure) one year ago?

Background on the question:

The wording of parapgraph 180 was amended in the "Amended Implementing Technical Standards" published on 18 March 2015. According to paragraph 180 (ITS published 30th July 2014) forborne exposures under probation period that have been reclassified out of the non-performing forborne exposures shall be reported separately within the performing exposures with forbearance measures in the column “of which: Performing forborne exposures under probation”. According to paragraph 180 (Amended ITS published on 18 March 2015) forborne exposures under probation that have been reclassified out of the non-performing exposures category shall be reported separately within the performing exposures with forbearance measures in the column "of which: Performing forborne under probation". Q&A 2014_878 is not applicable as it relates to the probation period and does not relate explicitly to column 050.

Date of submission:
22/06/2015
Published as Final Q&A:
13/12/2019
EBA Answer:

Paragraph 261, Annex V, Part 2 of Commission Implementing Regulation (EU) No 680/2014 (as amended) states that:


[…] Performing forborne exposures under probation that have been reclassified out of the non-performing exposures category shall be reported separately within the performing exposures with forbearance measures in the column ‘of which: Performing forborne exposures under probation reclassified from non-performing’.


The scope of this requirement is to monitor exposures that that have been reclassified out of the non-performing forborne category and are under the probation period.


It should be stressed that, where additional forbearance measures are applied on these exposures or these exposures become more than 30 days past due, the exposures shall be classified as non-performing in accordance with paragraph 260.


Regarding the examples, Exposure A shall be reported in column 050 whereas Exposure B shall not.

Status:
Final Q&A