How should we treat off-balance sheet exposures measured at reporting date at fair value trough P&L from the reporting templates F 18.00 and F 19.00 point of view? Shall we include them into templates or not?
Paragraph 217 in Annex V states:
"For the purpose of template 18, ‘exposures’ shall include all debt instruments (debt securities and loans and advances which shall include also cash balances at central banks and other demand deposits) and off-balance sheet exposures, except those held for trading exposures".
On the other hand, paragraph 234 in the same Annex states:
"Where IFRS or the relevant national GAAP based on BAD provide for the designation of commitments at fair value through profit and loss, the carrying amount of any asset resulting from that designation and measurement at fair value shall be reported in ‘Financial assets designated at fair value through profit or loss’ (IFRS) or ‘Non-trading non-derivative financial assets measured at fair value through profit or loss’ (national GAAP based on BAD). The carrying amount of any liability resulting from that designation shall not be reported in template F18. The notional amount of all commitments designated at fair value through profit or loss shall be reported in template 9."
In our understanding, aforementioned definition of exposures in paragraph 234 exclude all off-balance sheet exposures, measured at reporting date at fair value through P&L, irrespective of the fact that after drawing into balance sheet these exposures will be part of one of the portfolios of financial assets, measured at fair value through P&L. We believe that all off-balance exposures irrespective of the method of measurement and classification in accounting portfolios should be in the scope of non-performing definition (as is the case with balance sheet exposures). Otherwise, from the supervision point of view, we would not have a complete overview of the actual extent of non-performing exposures and the calculated NPE ratio would be incorrect.
Under IFRS 9 off-balance exposures (such as loan commitments and financial guarantees) may be designated at inception as financial liabilities at fair value through profit or loss (see IFRS 9, paragraphs 2.3 and B.2.5) and therefore they are excluded from the scope of the impairment requirements (see IFRS 9, paragraph 5.5.1).
Consequently, in accordance with paragraph 234 of Annex V to the ITS on Supervisory Reporting:
In addition, in the template F 09.01.01, where off-balance sheet items measured at fair value are considered as non-performing, their nominal amount and accumulated negative changes in fair value due to credit risk shall be reported in rows 021, 101 and 181 and in columns 120 and 130.