Dear Could it be that the the column "Accumulated negative value adjustments on LOCOM assets - credit risk induced" is missing in the validation rules from v5476_m until v5489_m?
According to the definition of accumulated impairment (annex V paragraph 71) "Under national GAAP based on BAD, it shall include specific and general allowance for credit risk, as well as the general allowance for banking risk where it reduces the carrying amount of debt instruments. Accumulated impairment shall also include the credit risk-induced value adjustments on financial assets under LOCOM." As " the credit risk-induced value adjustments on financial assets under LOCOM" are not presented in the "allowance" columns of 04.09 and 04.10 but are represented in c130 on F18, there could be a trigger of the validation error.
Under national GAAP, debt instruments at cost or at amortized cost reported under template F18 shall encompass instruments classified under strict of moderate LOCOM according to paragraph 233 of Annex V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting).
Column 130 of template F18 “Accumulated impairment, accumulated negative changes in fair value due to credit risk and provisions shall include credit risk-induced value adjustments of financial assets under LOCOM according to Annex V paragraph of the same regulation.
Consequently, validation rule v5476_m is not correct and will be deactivated until amendment to include column 080 “Accumulated negative value adjustments on LOCOM assets-credit risk-induced” of templates F4.9
The same applies to validation rules v5477_m to v5489_m.
* The answer to the Q&A presented here was amended on 21/01/2020 to ensure consistency with the instructions in Annex V, Part 2, paragraph 233 of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting).