Single Rulebook Q&A

Question ID: 2018_3716
Legal act : Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 – CRR2
Topic : Supervisory reporting
Article: 99
Paragraph:
Subparagraph:
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph : Annex III, F 02.00
Type of submitter: Competent authority
Subject matter : Reporting of financial asset sales and write-offs in FINREP template F 02.00
Question:

How should financial asset (e.g. loan portfolio) sales and write-offs be reported in the template F 02.00 (Statement of profit or loss)?

Background on the question:

Some banks report loan portfolio sales and write-offs in F 02.00 on a gross basis. Consequently when impairment is linked to the loan (measured at amortised cost), banks report reversal of impairment in row 460.

Examples:

1.     Loan portfolio sale:

o    Gross carrying amount: 100

o    Accumulated impairment: - 70

o    Net carrying amount: 30

o    Selling price: 35

Some banks report the transaction in the following way:

o    row 220 (Gains or (-) losses on derecognition of financial assets and liabilities not measured at fair value through profit or loss): 35-100 = - 65
OR
row 350 (Other operating expenses) +100-35= 65 (loss)

o    row 460 (Impairment or (-) reversal of impairment on financial assets not measured at fair value through profit or loss): - 70 (impairment gain)

2.     Write-off

o    Gross carrying amount: 100

o    Accumulated impairment: - 90

o    Amount written-off: 100

Some banks report write-offs in the following way:

o    row 220 (Gains or (-) losses on derecognition of financial assets and liabilities not measured at fair value through profit or loss): - 100 (loss)

o    Row 460 (Impairment or (-) reversal of impairment on financial assets not measured at fair value through profit or loss): - 90 (impairment gain)

In our understanding IFRS doesn’t require the gross basis presentation (IFRS 9 3.2.12), thus sales and write-offs should be reported on a net basis in F 02.00. Therefore the decrease in the loss allowance due to the amounts written off or sold shouldn’t be reported in F 02.00 as a reversal of impairment.

Date of submission: 16/02/2018
Published as Final Q&A: 14/12/2018
EBA answer:

According to IFRS 9.3.2.12, derecognition of financial assets should be recognized in profit and loss as the difference between the carrying amount (measured at the date of derecognition) and the consideration received.

Consequently examples 1 and 2 should be reflected in the FINREP templates of Annex III to Regulation (EU) 680/2014 (ITS on Supervisory Reporting) as follows:

 

Example 1

Journal Entry

   
     

 

DR

CR

Accumulated impairment

70

 

Cash

35

 

Loans

 

100

Gains on derecognition or other relevant P&L posotion

 

5

 

 

Statement of financial position (F 01.01)

 
     

010

Cash, cash balances at central banks and other demand deposits

 

020

Cash on hand

35

     

Statement of profit and loss (F 02.00)

 

The effect of the loan portfolio sale is recorded in the P&L on a net basis (5 CU).

     

 

In the example n. 2 the treatment related to a write-off is the following:

 

 

Example 2

Journal Entry

   
     

 

DR

CR

Accumulated impairment (from previous periods)*

90

 

Write-off (directly through P&L)

10

 

Loans

 

100

* Use of allowances for write-offs

 

Statement of profit and loss (F 02.00)

 

Given that the accumulated impairment of 90 was recognised in previous accounting years, the P&L for the current accounting year includes the following entry:

     

460

(Impairment or (-) reversal of impairment on financial assets not measured at fair value through profit or loss)

10

491

(Financial assets at amortised cost)

10

 

Status: Final Q&A
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