Question ID:
2018_3673
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 241/2014 - RTS for Own Funds requirements for institutions
Article/Paragraph:
1
Disclose name of institution / entity:
No
Type of submitter:
Consultancy firm
Subject Matter:
Taxonomy 2.7.0.1 Validation Rules on FINREP 12.01
Question:

According to rule v5054_m, the total of the stage one allowance is limited to the provision for expected losses on household exposures only. Should this rule be superseded by v5554_h? Using the former rule will understate the true amount of the allowance.

Background on the question:

Implementation and testing of EBA validation rules for taxonomy 2.7.0.1 suggests that there is some inconsistency between rule v5054_m and v5554_h. There is also a similar issue with rules v5055_m and v5555_h respectively rules v5056_m and v5556_h.

 

Date of submission:
20/01/2018
Published as Final Q&A:
06/04/2018
EBA Answer:

Row 160 ‘of which: collectively measured allowances’ of template F 12.01 of Annexes III and IV to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) and the row 170 ‘of which: individually measured allowances’ of template F 12.01 are related to all exposures in stage 1.

As a consequence the validation rule v5054_m is correct since the sum of row 160 and row 170 of template F 12.01 is equal to row 010.

The validation rule v5554_h cannot supersede v5054_m since it allows another check: in particular, it verifies that the sum of row 020 ‘debt securities’ and row 080 ‘loans and advances’ is equal to row 010.

Also the validation rules v5055_m and v5056_h are correct.

Status:
Final Q&A