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List of Q&A's

Financial guarantees received reported in table 9.2 and table 13.1

Should Financial Guarantees recieved reported in table 13.1 equal financial guarantees in table 9.2?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_338
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2014

Reporting thresholds - entry and exit criteria

Institution shall start reporting information subject to thresholds from the next reporting reference date where they have exceeded the threshold on two consecutive reporting reference dates. Is our understanding correct that if an institution exceeded the thresholds as of December 31 an September 30 the first reporting should be submitted for the reference date December 31? Institutions may stop reporting information subject to thresholds from the next reporting reference date where they have fallen below the relevant thresholds on three consecutive reporting reference dates. Based on the same methodology we assume that if an institution has fallen below the thresholds as of December 31, September 30 and June 30 no reporting is required as of December 31. Is our understanding 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_337
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Security code if no ISIN code available

If there are no ISIN code or other public codes that uniquely identifies the instrument, what should then be filled in in table F 40.2 column 010?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_336
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Reporting of entity level

In table F 40.01, Annex III, the group structure should be reported entity-by-entity. Question: What is the level of detail required in this table? Approach 1: only subsidiaries Approach 2: subsidiaries of subsidiaries (i.e. all companies in the group) Example: Group XYZ comprises Parent A which owns sub-group B and subgroup C. Both subgroup B and C are part of the CRR base of consolidation. Should the Group XYZ report in table 40.01 only the first level of subsidiary in subgroup B and C (I.e. parent company of sub-groups B and C) or also all companies owned by sub-group B and C?

  • 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: 2013_334
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Missing LEI code

What should be reported in column 010 in table F 40.01 Annex III and in column 025 in table C 06.00 Annex I, if LEI code is missing for an entity? Should the cell 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: 2013_333
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Where to report Retail card operations, card fees and acquiring fees

In which row should Retail card operations, card fees and acquiring fees be reported in template F 22.01, Annex III (Fee and commission income and expenses by activity)?

  • 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: 2013_331
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Interpretation of domestic

A bank have the Parent company incorporated in Sweden with branches and subsidiaries abroad within and outside EC. Shall instructions in ITS Annex V §107 for template 20.1, 20.2 and 20.3 be interpreted: · Domestic activities= activities in the country of the Financial Group that submits the report = Sweden? · Domestic activities= activities in the countries of Members states = European Community?

  • 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: 2013_330
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Reconciliation of assets and liabilities in reinsurance and insurance contracts

A bank has an insurance sub-group with unit-link insurance plans (aka ULIP. ULIPs give the holder the ability to invest in financial instruments and be hold the insurance contract) and traditional life insurance contracts. The insurance sub-group is fully consolidated in the Group (IFRS scope) but not consolidated in the Financial Group (Finrep scope). Shall instructions in ITS Annex V §105, §106 for template 17.1 row 270 and template 17.3 row 170 be interpreted: · Strict: only to be used for insurance contracts, or · Wide: to be used for both insurance contracts and investment contracts (i.e. ULIPs)

  • 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: 2013_329
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Short positions

There is no row for "short positions" in table F 16.01. According to the instructions short positions may not be included in Other financial liabilities. Where should short positions be included instead?

  • 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: 2013_328
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2014

Artikel 115 (3) Zuordnung von Religiongemeinschaften zu Forderungsklasse/ Attribution of religious communities to an exposure class

Was ist mit der Aussage im 3. Satz gemeint: In diesem Fall gilt Absatz 2 nicht..." ? English translation: What does the statement ‘In this case, paragraph 2 shall not apply…’ in Article 115(3) mean?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_327
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 08/11/2013

Movements in allowances

Assume that we have an opening balance with a collective allowance of 25 (25 % x 100) for an unimpaired loan. The loan becomes impaired and therefore we make a specific allowance of 100 (100 % x 100) during the period. The collective allowance is re-calculated to 0 CU (25% x 0) at end of period. How shall it be reported: · Specific allowance on row 090/column 020 of 100? · Collective allowance on row 320/column ??? of -25? · Giving a net on row 530/column 060 of 75, or ?

  • 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: 2013_326
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Counterparty breakdown

To be able to report the counterparty breakdown in the FINREP tables in Annex III (e.g. F 04.01 - F 04.04) the Swedish sector-/counterparty codes has to be sorted into the FINREP counterparty breakdown according to the instructions in in Annex V, Part 1.35. However, the instructions are not always clear enough. E.g.: Definition of credit institutions: EBA instructions (published 26th July 2013) do not provide complete information on the definition of credit institutions. The definition of credit institutions comprises only banks and multilateral banks. Other types of credit institutions are not mentioned at all in counterparty sector definitions. In March 2012, EBA and ECB developed a joint document bridging between FINREP and BSI (“Bridging the reporting requirements regarding ESCB Balance Sheet and Interest rate statistics with EBA Guidelines on FINREP, COREP and Large exposures”) In this document, all MFIs that are credit institutions (i.e. excluding central banks and money market funds) shall be regarded as credit institutions in FINREP. As referenced by ECB to Directive 2000/28, an MFI Credit institution is either: “an undertaking whose business is to receive deposits or other repayable funds from the public and to grant credits for its own account” “an electronic money institution… on the taking up, pursuit and prudential supervision of the business of electronic money institutions”. Question: Which definition should be used in FINREP? Are credit institutions only banks and multilateral banks or all MFI satisfying the ECB to Directive 2000/28? There is a obvious risk that institutions will make different interpretations with unclear guidance.

  • 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: 2013_325
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Liechtenstein is menber of EEA and uses Swiss Francs (CHF).

Liechtenstein is a member of the EEA, but uses Swiss Francs as a domestic currency. Switzerland is not a member of the EEA. Are Swiss Francs to be regarded as a domestic currency like the Euro for the purpose of paragraph 5.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_323
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of credit & liquidity facilities art 424.(5)

What amount should be included in the column 'outflow', rows 1260-1330 of template C.52 ?

  • 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: 2013_322
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 28/03/2014

Changes in fair value due to credit risk

What methodology should be used to calculate “Accumulated changes in fair value due to credit risk” required in EBA-ITS-2013-02, Annex III, Table 4.1 “Financial assets held for trading”?

  • 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: 2013_321
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

F 15 Amounts derecognised for capital purposes

We would please like to know in more detail than provided through legal references what information is required in F 15 col. 110 "Amounts derecognised for capital purposes". Should the column comprise the assets treated as securitisation positions that have been deducted from Common Equity Tier 1? In other words, is it referred to those assets that receive the above-mentioned treatment based on CRR articles 243(1.b) and 244(1.b), which allow deduction of the 1250% risk weighted securitisation positions? Thanks in advance.

  • 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: 2013_320
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

How should IRB-institutions exclude exposures according to art 140.4?

Institutions should exclude the exposure classes in art 112 (a) to (f) when calculating the institution-specific countercyclical capital buffer rates. How should this be applied for Institutions that are not using the Standardised approach but IRB approach? It in addition not not clear in the instruction if C0903 should be filled in even though the directive not yet has been implemented in the country. I.e. should C0903 be filled in as per end March 2014, even though an Institution not should report any buffer as per that date?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_318
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Reporting of notional amount for the derivatives hedging different risks (table 11.1 FINREP)

If the same hedge derivative contract is used in different transactions (i.e. to hedge multiple risks), shall the nominal amounts be reported gross and multiple times (column 030, table 11.1)?

  • 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: 2013_316
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014

Calculation of outstanding Tier 2 capital, following pre-payment of amounts that have been amortised or phased-out

This question, background information and proposed answer are posed on behalf of an institution we supervise. In accordance with Regulation (EU) No 575/2013 (CRR), subordinated debt with defined maturity is gradually deducted from Tier 2 in each of the last five years. Amortization shall occur on the basis of the number of days that have passed in the last five years (Article 64). The institution considers the possibility to repay subordinated debt in the portion corresponding to the amortized amount, assuming that this will have no impact on the basis for the calculation on the amount classified as Tier 2. Is this interpretation correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_314
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 20/06/2014

Definition of Custody assets 'entrusted to other entities' (Table 22.2)

Definition of ‘Of which: entrusted to other entities’ (row 090) in Table 22.2. Are only assets held with sub-custodians of the reporting entity reported in row 090?

  • 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: 2013_313
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/03/2014