Question ID:
2015_2546
Legal Act:
Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 – CRR2
Topic:
Supervisory reporting
Article:
Article 99
COM Delegated or Implementing Acts/RTS/ITS/GLs:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph:
§41 instructions
Type of submitter:
Credit institution
Subject Matter:
Trades receivables towards Central Banks
Question:

Could you clarify why in the FIN 5 template, it is not possible to put an amount in the cell « Trades receivables towards Central Banks” (Row 30 Column 10)?

Background on the question:

According to §41c of the ITS instructions, “Trade receivables” include loans to other debtors granted on the basis of bills or other documents that give the right to receive the proceeds of transactions for the sale of goods or provision of services. This item includes all factoring transactions (both with and without recourse); Futhermore, Exposures shall be assigned to FINREP counterparty sectors according to the nature of the immediate counterparty. In case of factoring transactions of receivables towards Central banks, Central banks are considered the only counterparty, where should we report this amount? One of our entity’s client has supplied Central banks with services and has factored its receivables. Considering our only counterparty is now Central Banks, where should we report this amount in template FIN 5 ?

Date of submission:
31/12/2015
Published as Final Q&A:
04/10/2019
EBA Answer:

Trade receivables included under row 030 of FINREP template F5.1 are defined under paragraph 85 (c) of Annex V to Regulation (EU) N°680/2014 (ITS on Supervisory Reporting) and shall include all factoring and similar transactions where the reporting institution buys the trade receivables (both with and without recourse).

In addition, paragraph 44 (a) of Annex V of the ITS states that for  trade receivables, the immediate borrower shall be the counterparty obliged to pay the receivables, except in transactions with recourse, where the immediate borrower shall be the transferor of receivables where the reporting institution does not acquire substantially all the risks and rewards of ownership of the transferred receivables.

Consequently, receivables from Central Banks that have been fully factored (without recourse) to the reporting institution, should be reported by that institution under column 010 (Central banks) of row 030 –Trade receivables.

In order to allow reporting in such case, the related cell (row 030, column 010) should be un-greyed in template F5.1 and validation rule v0874_m should be updated in order to include the un-greyed cell : under column 010, row 080 = rows 010+020+030+040+050+060+070.

Status:
Final Q&A