Single Rulebook Q&A

Question ID: 2019_4537
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: Not applicable
Article/Paragraph : Annex XV
Type of submitter: Credit institution
Subject matter : COREP C06.01 template - Consistency of the EBA taxonomy control v6288_m
Question:

Is the control v6288_m consistent with the COREP ITS?

Background on the question:

The control checks the following formula in the C06.01 template: {c410} = {c420} + {c430} + {c440} + {c450} + max({c470}, {c480} Nevertheless, the C06.01 template is the total of the C06.02 that is presented entity by entity, and for which the same control is already performed (v6289_m) Consequently, the control that is verified by entity in the C06.02, cannot be verified in the total C06.01 as demonstrated in the following example with 2 entities A and B: (attached file)

Date of submission: 11/02/2019
Published as Final Q&A: 12/07/2019
EBA answer:

As stated in Q&A 2014_1192 and in the instructions for columns 410 to 480 of C06.02 (Annex II of Regulation (EU) 680/2014, ITS on Supervisory Reporting), the reported amounts in these columns represent the contributions of each entity to group capital buffers, and are based on provisions applicable to determine the buffer requirements for the consolidated situation of a group. Therefore, if a group is subject to a GSII and OSII requirement, the higher shall apply according to the provisions in article 131(14) of Directive 2013/36/EU (CRD IV). Since it is these amounts that have to be broken down by investee according to their contribution to the group, there should not exist a situation in which the GSII is higher (or lower) than the OSII for the totals while being lower (or higher) for a particular investee.

In the example provided by the submitter, the group amounts on a consolidated basis seem to be 10 (as per GSII requirement) and 30 (as per OSII requirement). These amounts should be broken down by contribution to the group among investees A and B, where c480 will always be higher than c470 and therefore c410 will always include c480 and not c470. In this way, validation rule v6289_m holds also for C06.01 template.

The same rationale holds for validation rule v6290_m.

Status: Final Q&A
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