Single Rulebook Q&A

Question ID: 2018_4064
Legal act : Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 – CRR2
Topic : Supervisory reporting
Article: Annexes I and II, CRR
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 : Annexes I and II, CRR
Name of institution / submitter: Bank of Cyprus Public
Country of incorporation / residence: Cyprus
Type of submitter: Credit institution
Subject matter : Inconsistency in validation rule eba_v4721_m
Question:

Validation rule v4721_m, is introduced for template C 07.00. R015 of C 07.00 template is reported for exposures classes “016-Equity” and “012- Items associated with particularly high risk”, as well as the “001-Total” template. C 07.00 r015 of CRSA has the same reporting nature as C 07.00 r040 and all the memorandum items in C 07.00 i.e. they are reported in specific exposure classes but they are reported in total as well. Additionally, ITS on “REPORTING ON OWN FUNDS AND OWN FUNDS REQUIREMENTS” under section 3.2.2 “Scope of the CR SA template” par. 49 states that “The information in CR SA is requested for the total exposure classes and individually for each of the exposure classes as defined for the standardised approach. The total figures as well as the information of each exposure class are reported in a separate dimension.” denoting that sheet “001 – Total” is the sum of all the subsequent sheets falling under C 07.00. Therefore we believe that “001 – Total” sheet of C 07.00 has been correctly populated.

Background on the question:

ITS on “REPORTING ON OWN FUNDS AND OWN FUNDS REQUIREMENTS” under section 3.2.2 “Scope of the CR SA template” par. 49 states that “The information in CR SA is requested for the total exposure classes and individually for each of the exposure classes as defined for the standardised approach.

Date of submission: 29/06/2018
Published as Final Q&A: 11/01/2019
EBA answer:

Validation rule v4721_m states that, for all columns of the C 07.00.a template, the following sheets [(001;002;003;004;005;006;007;008;009;010;011;013;014;015;017)] should have {r015} = 0.

According to Annex II to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting): 3.2.2. Scope of the CR SA template – paragraph 49: the information in CR SA is requested for the total exposure classes and individually for each of the exposure classes as defined for the standardized approach. The total figures as well as the information of each exposure class are reported in a separate dimension.

Additionally, on the instructions of ITS, row 015 of C 07.00 template, it is specified: If an exposure is either listed in Article 128(2) of CRR or meets the criteria set in Articles 128(3) or 133 of CRR, it shall be assigned to the exposure class ‘Items associated with particular high risk’ or ‘Equity exposures’.

Consequently, there should be no other allocation, even if the exposure is defaulted according to Article 127 of Regulation (UE) No 575/2013. This is the reason why sheet 012 (Items associated with particular high risk) and sheet 016 (Equity exposures) are excluded from the validation rule v4721_m as amounts different than zero could apply to them.

Sheet 001 (Total) is not an exposure class defined in article 112 of the Regulation (EU) Nº 575/2013. Therefore, it must totalize the amounts coming from each exposure class.

Since the total sheet includes the amounts reported in sheet 012 (Items associated with particularly high risk) and sheet 016 (Equity exposures) where amounts different than zero may be reported, sheet 001 (Total) could have amounts different from zero reported.

Having said that, ITS will be amended in order to allow values different from zero in row 015 of C.07.00 template.

Status: Final Q&A
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