Single Rulebook Q&A

Question ID: 2018_3934
Legal act : Directive 2013/36/EU (CRD) as amended
Topic : Supervisory reporting
Article: Article 78
Paragraph:
Subparagraph:
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulatory Technical Standard on benchmarking portfolios
Article/Paragraph : Validation Rules
Type of submitter: Individual
Subject matter : Meaning of current year in validation rule v6167_m
Question:

What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

Background on the question:

For v2.8 framework version, a new validation rule was added, v6167_m, C 101.00:  {c050} <= 31-Dec-'current year-1'. Please help me with some clarification regarding the current year interpretation in this formula.

From a technical perspective it is a little bit confusing as end of year might be considered reference date of report and this might have a totally different meaning than the current year.

Date of submission: 25/05/2018
Published as Final Q&A: 29/03/2019
EBA answer:

Commission Implementing Regulation (EU) 2016/2070 specifies the instructions for the reporting of supervisory benchmarking of internal approaches for calculating own funds requirements, according to article 78(2) of Directive 2013/36/EU. In particular, according to the instructions referred to in Table C 101 of Annex IV, column 050 (“Date of most recent rating of counterparty”) shall contain the date of the most recent rating of the counterparty.

Validation rule v6167_m further specifies that the most recent rating date shall be reported, as long as it falls within the time frame of the benchmarking exercise. For example, let us consider a counterparty that has received a rating on February 2017, October 2017 and February 2018. For the benchmarking exercise of December 2017 the rating that occurred in October 2017 shall be considered, even if there exists a later rating taking place before the actual reporting date.

Disclaimer:
The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal. The text of the Implementing Regulation may differ from the text of the draft ITS to which this Q&A refers.
 
Status: Final Q&A
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