Question ID:
2019_4727
Legal Act:
Regulation (EU) No 575/2013 (CRR) as amended
Topic:
Supervisory reporting - Funding Plans
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions
Article/Paragraph:
Annex 1
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
Funding plan validation error v6223_m
Question:

Can a credit institution submit a funding plan with having an actual reverse repurchase agreement starting position and no projected positions in view of validation error v6223_m (template P01.03)?

Background on the question:

Template P01.01 requires the submission of the actual asset position as at reporting date (31 December 2018), and projected/planned position in 6 months, 1 year, 2 year and 3 years’ time. The Bank received a validation error (v6223_m) for reverse repurchase agreements since it had an actual position at 31 December 2018, but then submit nil values in all of the projected years. When preparing budgets, the Bank does not typical project such items within its forecasts.

Date of submission:
17/05/2019
Published as Final Q&A:
08/05/2020
EBA Answer:

V6223 is a completeness/consistency check. The assumption behind this check is that all actual asset positions with a positive value reported as of the current reference date are expected to also have a positive value at future reference dates. V6223 is defined as a validation rule with the severity ‘warning’. Warnings may neither be applicable to all reporters nor to all reference dates. Hence, if the bank indeed planned to have a reverse repo position of zero in future years, the validation rule (warning ) will not hold but will be explained (Annex XV, spreadsheet “Explanations”).

Status:
Final Q&A