Is the EBA expecting a specific relation between the column 020 in the COREP C06.02 and the column 020 of the FINREP F40.01 template ? The annexes 2 (solvency) and 5 (FINREP) of the regulation 680/2014 do not bring any information regarding an expected accordance, and only indicate that the code should be unique for each line of the template. However, those codes seem to have the same purpose, and the same entities are likely to be reported on those templates on each remittance. Therefore : - Is an entity reported in both C06.02 and F40.01 supposed to share the same code on the columns 020 of the both templates? - Is an entity reported in one of those templates supposed to share the same code in the next remittance of the template? Similar questions can be asked regarding the columns 010 of the large exposures templates (C27 to C31).
The national competent authorities being in charge of the data quality controls, comparisons have been made between the scope of consolidation reported on risk templates (C06.02) and the accounting templates (F40.01). The question of automatic controls between those templates was raised and needs precisions regarding the links between those two templates.
Annex II and Annex V currently do not contain detailed information on this topic. However, Annex IX of the ITS contains the following instructions regarding column 010 in template C 27.00:
“The code is a row identifier, and must be unique for each row in the table. The code shall be used to identify the individual counterparty. However, the purpose of this column is to link counterparty details in C 27.00 with exposures reported in C 28.00 – C 31.00. The code of the group of connected clients shall not be reported, unless the national reporting system provides a unique code for the group of connected clients. The codes shall be used in a consistent way across time”.
Thus, the code used in templates C 27.00 – C .31.00 should be identical for a given counterparty.
In contrast, Annex II and Annex V respectively do not contain explicit instructions as to the relation of the Legal entity code between templates C 06.02 and F 40.01. However, given that a comparison between the consolidation scope used for accounting and prudential purposes is important from a supervisory perspective, it is assumed that a given entity has the same code in both templates.
Even if those templates are provided by different systems in the banking institutions e.g. COREP template is provided by the risk system, while the FINREP template is provided by the financial system a mapping within the banking institution must be possible to ensure that only one entity code is used for supervisory reporting purposes. This is especially relevant for entities that do not have a Legal Entity Identifier (LEI).
The ITS will be amended in order to reflect this relation more clearly.