Single Rulebook Q&A

Question ID: 2018_3672
Legal act : Regulation (EU) No 575/2013 (CRR) as amended
Topic : Supervisory reporting
Article: 99
Paragraph: 5
Subparagraph:
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph : REGULATION (EU) 2017/2114 amending Regulation (EU) No 680/2014
Name of institution / submitter: Sopra banking Software
Country of incorporation / residence: France
Type of submitter: Consultancy firm
Subject matter : Template CRGB sheet 01 and 02
Question:

In Regulation (EU) 2017/2114 amending Regulation (EU) No 680/2014, in Annex II paragraph 3.4, no sheet ‘Total’ is described for CRGB1 and CRGB 2. Only in paragraph 3.4.4.1 a sheet Total is described for CRGB 04.
But a release note on taxonomy 2.7 seems to say that a total sheet is now mandatory for CRGB1 and 2. Is it true?
There are 63 validation rules between templates C 09.01 and C 07.00 which have an expression similar to this ‘sum({C 09.01.a, r010, c010, (sNNN)}) = {C 07.00.a,  r010,  c010,  s002}’.
Additionally, there are 76 new validation rules of type eQuivalence which have an expression similar to this ‘{C 09.01.a,  r010,  c010,  [CEG=eba_GA:x1]} = {C 07.00.a,  r010,  c010,  s002}’.
There are also 39 validation rules between templates C 09.02 and C 08.01 which have an expression similar to this ‘sum({C 09.02, r130, c010, (sNNN)}) = {C 08.01.a, r010, c020, s017}’.
Which of these rules and how shall these rules be applied successfully?

Background on the question:

Extract of the release note taxonomy 2.7:
New approach for reporting of totals on templates with open sheets applied to C 09.01.a, C 09.01.b, C 09.02 (for which totals will now be reportable), C 09.04 and C 15.00 (for which the previous reporting approach is changed), and the new tables C 33.00.a and C 33.00.b.
- A new member ‘All countries’ (x1) has been added to the GA domain.
- New hierarchies GA5_2 and GA6_1 created similar to GA5_1 and GA6 but with the new ‘All countries’ member in between ‘All Geographical Areas/Not specified’ (x0) and the leaf Members.
- The z-axis of templates C 09.01, C 09.02, and C 09.04 is restricted to any member of the GA5_2 hierarchy other than the root ‘All Geographical Areas/Not specified’ (x0). I.e. the new ‘All countries’ member is allowed, but the x0 member is not. Similarly, the z-axis of C 15.00 is restricted to any member of GA6_1 except x0.
- The ‘total’ figure requested by the ITS should, for these templates, be reported against this new ‘All countries’ (x1) member. o New validation rules linking cells on these total sheets to other templates, and in one case the sum of the country breakdown figures to the reported total figures have been introduced, which use a new notation to indicate ‘filtering’ (restriction to a specific value or subset of values) on the z-axis. E.g.
o {C 09.01.a, r070, c010, [CEG=eba_GA:x1]} = {C 07.00.a, r010, c010, s008}
o {C 09.04, [CEG=GA:x1]} = sum({C 09.04, ([CEG!=GA:x1]) })
- The existing approach to reporting of ‘total’ figures is for now retained on C 51.00 – C 54.00, C 60.00, C 61.00, and C 66.00 – C 76.00 (where an explicitly modelled sub table contains the total figures).
If a total sheet is introduced in template C 09.01, the sum on left hand side of a validation rule will become double than the expected value and will always result in a failure of the validation rule. For example, in template C 09.01, the sum of values on individual country sheets is X for a given data point and the value of a particular data point in template C 07.00 is also X. But, with a total sheet in place, the rule will equate to 2X = X resulting in failure.
Following is the list of the 63 validation rules for C 09.01 / C 07.00: v0350_m, v0351_m, v0352_m, v0353_m, v0354_m, v0355_m, v0356_m, v0357_m, v0358_m, v0359_m, v0360_m, v0361_m, v0362_m, v0363_m, v0364_m, v0365_m, v0366_m, v0367_m, v0368_m, v0369_m, v0370_m, v0371_m, v0372_m, v0373_m, v0374_m, v0375_m, v0376_m, v0377_m, v0378_m, v0379_m, v0380_m, v0381_m, v0382_m, v0383_m, v0384_m, v0385_m, v0386_m, v0387_m, v0388_m, v0389_m, v0390_m, v0391_m, v0392_m, v0393_m, v0394_m, v0395_m, v0396_m, v0397_m, v0398_m, v0399_m, v0400_m, v0401_m, v0402_m, v0403_m, v0404_m, v0405_m, v0406_m, v1666_m, v1667_m, v1668_m, v1669_m, v1670_m, v1671_m
Following is the list of the 76 new validation rules of the type eQuivalence for C 09.01 / C 07.00: v5745_q, v5746_q, v5747_q, v5748_q, v5749_q, v5750_q, v5751_q, v5752_q, v5753_q, v5754_q, v5755_q, v5756_q, v5757_q, v5758_q, v5759_q, v5760_q, v5761_q, v5762_q, v5763_q, v5764_q, v5765_q, v5766_q, v5767_q, v5768_q, v5769_q, v5770_q, v5771_q, v5772_q, v5773_q, v5774_q, v5775_q, v5776_q, v5777_q, v5778_q, v5779_q, v5780_q, v5781_q, v5782_q, v5783_q, v5784_q, v5785_q, v5786_q, v5787_q, v5788_q, v5789_q, v5790_q, v5791_q, v5792_q, v5793_q, v5794_q, v5795_q, v5796_q, v5797_q, v5798_q, v5799_q, v5800_q, v5801_q, v5802_q, v5803_q, v5804_q, v5805_q, v5806_q, v5807_q, v5808_q, v5809_q, v5810_q, v5811_q, v5812_q, v5813_q, v5814_q, v5815_q, v5816_q, v6123_q, v6124_q, v6125_q, v6126_q
Following is the list of validation rules for C 09.02 / C 08.01: v0415_m, v0416_m, v0418_m, v0420_m, v0421_m, v0423_m, v0430_m, v0431_m, v0433_m, v0435_m, v0436_m, v0438_m, v0440_m, v0441_m, v0443_m, v0445_m, v0446_m, v0448_m, v0450_m, v0451_m, v0453_m, v0455_m, v0456_m, v0458_m, v0460_m, v0461_m, v0463_m, v0465_m, v0466_m, v0468_m, v0470_m, v0471_m, v0473_m, v0475_m, v0476_m, v0478_m, v1672_m, v1673_m, v1674_m

Date of submission: 19/01/2018
Published as Final Q&A: 06/04/2018
EBA answer:

In version 2.7 of the reporting framework, the technical foundations for reporting a ‘total’ sheet in templates C 09.01 and C 09.02 of Annex I to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) were laid, i.e. the DPM was amended to accommodate the reporting of these totals, However, the applicable version of the ITS on Supervisory Reporting does not establish the legal obligation to submit the corresponding data. This legal obligation is envisaged to be put in place with version 2.8 of the reporting framework and the corresponding amendment to the ITS on Supervisory Reporting.
Against this background, the 76 new validation rules of the type ‘eQuivalence’ comparing values between templates C 07.00 and C 09.01 are not applicable yet and will be deactivated for version 2.7 of the reporting framework. They will become valid in v2.8 of the reporting framework only.
On the other hand, the manual validation rules comparing values between templates C 07.00 and C 09.01 respectively between templates C 08.01 and C 09.02 continue to be applicable in version 2.7 and will be amended or dropped in version 2.8.
Institutions are advised not to submit a total for templates C 09.01 and C 09.02 in the context of version 2.7 of the reporting framework.

Status: Final Q&A
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