Question ID:
2019_4803
Legal Act:
Regulation (EU) No 575/2013 (CRR) as amended
Topic:
Supervisory reporting - FINREP (incl. FB&NPE)
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph:
Annexes III and IV
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
Validation rules v2.8.1
Question:

This question refers to the validation rule v5532_m. The prerequisites indicate that template F 04.02.2 triggers this validation rule. Specifically, the prerequisites are : F 06.01 and (F 04.02.1 or F 04.02.2 or F 04.03.1 or F 04.04.1). In the French Gaap environment, only F 04.02.2 is defined as compulsory but not the other templates F 04.XX. For this reason the rule may not be valid in general because all the other files are not produced. For reminder the formula is {F 06.01, r190, c010} = {F 04.02.1, r160, c010} - {F 04.02.1, r160, c020} + {F 04.02.2, r170, c010} - {F 04.02.2, r170, c020} + sum({F 04.03.1, r160, (c015, c030, c040)}) + sum({F 04.04.1, r120, (c015, c030, c040)}) Could it be possible to modify the appliance conditions of this Validation Rule ? Will it be corrected in a further evolution of the EBA VR ? Thanks

Background on the question:

The question aims to reduce the number of potential recurrent checks linked with the EBA validation rules

Date of submission:
21/06/2019
Published as Final Q&A:
08/05/2020
EBA Answer:

Validation rule v5532_m stipulates equivalence between non-trading loans and advances to non-financial corporation in template F 06.01 and the corresponding amounts broken down by accounting portfolios. This validation rule is intended for IFRS reporters, while v5533_m for nGAAP reporters.
In case nGAAP reporters are required by the competent authority to report some of IFRS-related templates in addition to nGAAP-related templates, validation rule v5532_m is not applicable. The severity level of v5532_m will be set to “warning”; it will admit therefore failures provided that “clear explanations about failure […] [are] provided to the relevant competent authority where needed.” (Explanation tab to EBA Validation Rules file).
Since the scope of the failure is supposedly quite narrow, prerequisites of validation rule v5532_m will not be amended.

Status:
Final Q&A