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List of Q&A's

LR1 on alternative treatment of the exposure measure - accounting balance sheet value

Does the "accounting balance sheet values" as reported in LR1 include credit risk mitigation effects? The difference between column 010 (accounting balance sheet value) and column 020 (accounting value assuming no netting or other CRM) will then be based on credit risk mitigation effects (crm/netting)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1131
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 05/03/2021

FINREP F 40.2

In the Q&A 2013_93 und 2013_344 you have published clarification regarding the requirements of table 40.2. You stated that all securities issued by an entity included in the accounting scope of the group which holds the securities in their individual balance sheet, shall be reported. Table F 40.02 is to be viewed from the point of view of the entity holding the equity instruments that are included in the accounting scope of consolidation (i.e. subsidiaries, joint ventures and associates). Shall this table comprise only investments/securities that are hold by more than one holding company (Option 1) or each investments / security within the accounting scope of consolidation (Option 2). Thus is the base of investments / securities equal to table 40.1? Please see the example in the excel-sheet.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1130
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

F 09.02 & F 13.01: Maximum amount of the guarantee that can be considered

Please we would like to know what the differences are between the reporting of the "maximum amount of guarantee that can be considered" in templates F 09.02 and F 13.01. Why are these concepts not equal?In question ID 2013_338 it is stated:(...) since for F 09.02, the amount is the maximum amount the counterparty could have to pay if the guarantee is called on, and in table F 13.01, the amount of guarantee shall not exceed the carrying amount of the related loan.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1129
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

FINREP reporting requirements

If an institution is currently not within the scope of FINREP (i.e. not subject to article 4 of Regulation (EC) No. 1606/2002), but may fall within the scope of FINREP in the future, what would be the institution's first reporting reference date for FINREP?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1128
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Commencement of 3-month period when CCPs cease to meet certain conditions

Should the 3-month period available under Regulation (EU) No 575/2013 (CRR) Article 311, where a firm may continue to treat a CCP as QCCP following confirmation that the CCP no longer meets the conditions for authorisation or recognition, apply: (1) From the earlier of the date of ESMA negative confirmation of authorisation or recognition or from the end of the transitional period available for CCPs under CRR Articles 497(1) and 497(2); or (2) Only after ESMA has made an initial positive assessment of authorisation or recognition and the CCP fails to meet those conditions at a later date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1126
  • Topic: Market risk
  • Date of submission:

F 46.00 - changes in equity - other equity and total comprehensive income

Cell r200-c040 is marked as grey in FINREP table 46 and consequently this cell is not to be filled in. However, if a financial institution has classified "Total comprehensive income" in changes in equity under "Other equity" in its financial reporting based on IFRS, where are we to put this number?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1123
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Annex V - FINREP - Table 31.1 Related parties

In Annex V it is stated in paragraph 120 that "institutions shall include the portions of balances and transactions with joint ventures and associates of the group to which the entity belongs that have not been eliminated when either proportional consolidation or the equity method is applied." If a financial institution uses equity method for consolidation purposes for assiciates of the group, does this mean that column 030 in table F 31.01 is to be left empty?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1122
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

CR IRB (C08.01 and C08.02) template column 010 and CR GB (C09.02) column 080

In column 010 of templates C08.01 and C08.02 and column 080 of template C09.02, is the obligor PD reported before CRM effects and floors or after CRM effects and floors which is used in the RWA calculation reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements
  • ID: 2014_1117
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Non Performing Loans at group levels.

Clarification is requested as to when group (connected) accounts should be downgraded to the Non Performing category (NPL) when only one party from within this group classifies as an NPL (refer to the 2nd part of para. 155). Should group facilities be downgraded: 1. When exposures past-due by more than 90 days represent 20% of the gross carrying amount of a singly debtor (one party within group entities) or 2. When exposures past-due by more than 90 days represent 20% of the gross carnying amount of the total group exposure? or is this left at the discretion of the credit institution? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1113
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Content of “accumulated changes in fair value due to credit risk” in template F 16.05

Column 020 of template F 16.05 is labeled as “Accumulated changes in fair value due to credit risk”, whereas the respective instructions (paragraph 100 of part 2 of Annex V of the ITS on supervisory reporting) reads “Institutions shall report the net realised and unrealised and the amount of change in fair value in the period due to changes in the credit risk (own credit risk of the borrower or issuer).”. We would like to get confirmation that the instructions shall be followed and that the use of the word “accumulated” in the second column of F 16.05 is a typo.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1109
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Loans collateralized by immovable property in F 05.00 and F 13.01

Do loans collateralized by immovable property in template F 05.00 contain only residential and commercial immovable property, like in F 13.01, or are they open to other collateralized immovable property (those which do not meet the definition of residential and commercial provided by CRR)? If the former, are those loans collateralized by other immovable property reported as other loans collateralized?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1108
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Validation Rule v0629_m

Can rule v0629_m be valid in any case? Namely, in some cases (see background information) the own funds requirements for foreign exchange stipulate that the foreign exchange risk be calculated as the sum of its overall net foreign exchange position and its net gold position in the reporting currency, multiplied by 8 %, not by 12,5%, which is what the rules, in effect, validates.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1107
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Non-performing exposures - Cash balances at central banks, Non-current assets held for sale

Does template F18.00 DEBT INSTRUMENTS AT AMORTISED COST (rows 010 to 180) include Cash and cash balances at central banks portfolio? Does template F18.00 DEBT INSTRUMENTS AT FAIR VALUE other than HFT (rows 190 to 320) include Non-current assets and disposal groups classified as held for sale?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1106
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/11/2014

Groups including an investment firm referred to in Article 95(1) of the CRR controlled by a financial holding company or mixed financial holding company

How shall the own funds requirements be calculated for a group including an investment firm referred to in Article 95(1) controlled by a financial holding company or mixed financial holding company (and no credit institutions)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1105
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 01/08/2014

Significant risk transfer applicable to leverage ratio computation

Should the concept of significant risk transfer be applied to the leverage ratio computation of securitisations? Should the underlying exposures be taken into account in case of no significant risk transfer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1104
  • Topic: Leverage ratio
  • Date of submission:

Clarification regarding the legal opinion mentioned in Article 305 of Regulation (EU) No 575/2013 (CRR)

Is it correct to assume that the specific legal opinion mentioned as a prerequisite in Article 305(2)(c) CRR only needs to confirm that the other prerequisites 'individual client segregation' in Art 305(2)a) and the facilitation of the portability of client assets under Art 305(2)(b) are in place and fulfilled (in a sense that the respective legal position of the client is enforceable under respective law(s)), or does the legal opinion need to address additional legal questions beyond that scope? In the latter case what kind of legal questions beyond Art 305(2)(a) and (b) would such legal opinion need to address?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1102
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 01/08/2014

Validation Rule v2245_h

Should column 090 from form CR GB 2 still be in the scope of validation rule v2245_h? As the rule validates a sum and column 090 contains percentages it cannot be correct.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1101
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

FINREP Template 13.2 and 13.3

The difference between the templates 13.2 and 13.3 and the purpose of template 13.3 is not clear. Can you please explain the following questions.1.)Template 13.2 “Collateral obtained by taking possession during the period [held at the reporting date]”: We have understood that “during the period” means Information about obtained Collateral year-to-date (ytd). That means from 1. January to Reference date. Is this correct?2.)Template 13.3 “Collateral obtained by taking possession [tangible assets] accumulated”: We have understood that “accumulated” means life-to-date (ltd). Is this correct?3.)The heading of Template 13.3 is “Collateral obtained by taking possession [tangible assets] accumulated”. In de ITS part 2.84 you explain, that this template excluding those classified as “Property, plant and equipment”. For our understanding the definition of tangible assets are the same definition of Property, plant and equipment. Is the heading incorrect? If not, can you please confirm the purpose of this Template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1094
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Validation Rules: v0219_m, v0221_m

Both rules validate the Surplus(+) / Deficit(-) of certain capital:- v0219_m for CET1 Capital- v0221_m for T1 CapitalThe question stands: Should the range of percentages from Article 465 CRR be implemented in the validation rules for each type of capital or should the fixed percentages in Article 92 CRR be upheld?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1093
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016