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List of Q&A's

Deletion of several columns of COREP reports in Annex I

We have noted the deletion of several columns in several templates of Annex 1 of the COREP, detail below:    C 08.02 - CREDIT AND COUNTERPARTY CREDIT RISKS AND FREE DELIVERIES: IRB APPROACH TO CAPITAL REQUIREMENTS: BREAKDOWN BY OBLIGOR GRADES OR POOLS (CR IRB 2) Delete column 0210 RECEIVABLES C 08.05.1 - CREDIT RISK AND FREE DELIVERIES: IRB APPROACH TO CAPITAL REQUIREMENTS: BACK-TESTING OF PD IN ACCORDANCE WITH ARTICLE 180(1), POINT (f) OF REGULATION (EU) NO 575/2013 (CR IRB 5B) Delete column 0040 OBSERVED AVERAGE DEFAULT RATE (%) C 08.06 - CREDIT RISK AND FREE DELIVERIES: IRB APPROACH TO CAPITAL REQUIREMENTS: SPECIALISED LENDING SLOTTING APPROACH (CR IRB 6) Delete column 0090 EXPECTED LOSS AMOUNT Instructions for this column are maintained in Annex 2 C 14.00 - DETAILED INFORMATION ON SECURITISATIONS (SEC Details) Delete column 0300 LEGAL FINAL MATURITY DATE These deletions of columns do not seem justified to us, can you confirm that these columns are to be maintained in the different templates ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6706
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2023

COREP V3.2 – C13.01 – CREDIT RISK: SECURISATION (CR SEC)

The crossing of line 0430 RE-SECURITISATIONS with column 0160 (-) NON REFUNDABLE PURCHASE PRICE DISCOUNT, has been opened to data restitution, is this compliant? In the version of the European Commission this crossing did not allow the restitution of data. The crossing of line 0090 SECURITISATIONS: ON-BALANCE SHEET ITEMS with column 0870 ADJUSTMENT TO THE RISK-WEIGHTED EXPOSURE AMOUNT DUE TO MATURITY MISMATCHES, has been opened to data restitution, is this compliant? In the version of the European Commission this crossing did not allow the restitution of data.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6705
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2023

COREP v3.2 – C 33.00

Regulation (EU) 2022/1994 amending the implementing technical standards laid on in Implementing Regulation (EU) 2021/451 changes the direction of the 2nd parenthesis for the period intervals of rows 0170 to 0230, which generates a 'double counting', example below: r0170 [0 – 3M] r0180 [3M – 1Y] r0190 [1Y – 2Y] r0200 [2Y – 3Y] r0210 [3Y – 5Y] r0220 [5Y – 10Y] r0230 [10Y – more] The periods 3M, 1Y, 2Y, 3Y, 5Y and 10Y would be declared on 2 rows each time.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6704
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

COREP V3.2 - C 20.00 - MARKET RISK: STANDARDISED APPROACH FOR SPECIFIC RISK IN THE CORRELATION TRADING PORTFOLIO (MKR SA CTP)

Regulation (EU) 2022/1994 amending the implementing technical standards laid on in Implementing Regulation (EU) 2021/451 changes the meaning of the 2nd parenthesis for the weighting rate intervals of columns 0071 to 0096, which results in double counting. Example: C0071 [0 – 10%] C0072 [10 – 12%] C0073 [12- 20%] The same weighting rate would be declared in two columns, for example the rate of 12% would be declared in columns 0072 and 0073.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6703
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2023

Leverage - Traditional securitisations under article 244 (recognition of significant risk transfer) that should be included within the scope of article 429a paragraph 1 point m

Under Article 429a §1-m of CRR2, institutions may exclude from their total exposure measure the securitised exposures from traditional securitisations that meet the conditions for significant risk transfer (SRT), as per article 244(2).  May institutions also exclude from their total exposure measure the securitised exposures from traditional securitisations that are referred to in article 244-1-b) i.e. the securitisations under the 'full deduction' option where the originator institutions apply a risk weight of 1 250% to all retained securitisation positions or where these retained securitisation positions are deducted from Common Equity Tier 1 items in accordance with Article 36(1)(k) of the CRR ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6702
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 24/02/2023

COREP v3.2, C 19.00

Regulation (EU) 2022/1994 amending the implementing technical standards laid on in implementing Regulation (EU) 2021/451 changes the meaning of the 2nd parenthesis for the weighting rate intervals of columns 0061 to 0103, which generates 'double counting', example below: C0061 [0 – 10%] C0062 [10 – 12%] C0063 [12 -20%] The same weighting rate would have to be declared in two columns, for example the rate of 10% would have to be declared in column 0061 and in column 0062, which is not logical. In addition, column 0083 has been removed from the C19.00 template in the version of Official Journal of the European Union, while column 0104 is maintained. It doesn't seem consistent to us.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6701
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2023

Reporting of securitisations SWAP transactions in C 14.00 and C 14.01

Do the new columns below introduced with Regulation (EU) 2021/451 as amended by Regulation (EU) 2022/1994 (framework release v3.2) need to be completed for securitisations SWAP transactions ? Column 0287 of template C 14.00 : Synthetic excess spread Column 0362 of template C 14.01 : Synthetic excess spread Template C 14.00 Column 0076: TYPE OF EXCESS SPREAD Column 0077: AMORTISATION SYSTEM Column 0078: COLLATERALISATION OPTIONS Column 0254: OVERCOLLATERALISATION AND FUNDED RESERVE ACCOUNTS: AMOUNT Column 0255: OVERCOLLATERALISATION AND FUNDED RESERVE ACCOUNTS: OF WHICH: NON-REFUNDABLE PURCHASE PRICE DISCOUNT It does not seem relevant to us to supply these new columns for the scope of securitisation swaps, in particular when the latter are linked to the nominal loan pool.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6700
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/09/2023

Inflows or outflows on open SFT in the LCR computation

Considering the LCR scenario, which sets out a loss of value of collateral within the LCR horizon, should inflows on open reverse repos and outflows on open repos be accounted for in the LCR at the first date of renegociation, when this date falls within the LCR horizon?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2023_6699
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2023

Time horizon for partial expected shortfall calculation

According to Article 325bc(1) CRR, the Partial Expected Shortfalls (PES) used for the ES computation are determined by applying scenarios of future shocks with a 10-days time horizon. Are 10-days shocks mandatory or are other time horizons rescaled allowed? (Typically, is the use of 1-day shocks rescaled to 10-days horizon permitted?)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6698
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 01/03/2023

Inaccurate Measurement of the threshold “total annual gross revenue from investment services and activities of the investment firm” in the ITS on reporting for Investment Firms.

Is it correct that the calculation of the threshold “total annual gross revenue” in row 0110 of template I 05.00 of Annex II of the commission implementing regulation (EU) 2021/2284 includes the revenues stemming from the MiFID Ancillary Services listed in rows 0230 to 0290 even though the corresponding definition of this threshold in article 12 (1) (i) of the IFR is explicitly referring to “total annual gross revenue from investment services and activities of the investment firm” and therefore doesn’t include any revenues stemming from such ancillary services?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/2284 - ITS on Reporting
  • ID: 2023_6697
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2023

Inclusion of instruments in aggregated portfolios

In Annex 5, when calclulating risk measures for an aggregated portfolio, an instrument should enter the calclulation only once or each time it forms an individual portfolio?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6696
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 01/03/2023

ESG P3 - Templates 6, 7 and 8 - Scope of application as of 31.12.2023 and institutions’ exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024

Is the institution obliged to disclose Pillar III ESG templates 6, 7 and 8 as of 31.12.2023 despite its current exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6695
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

Overcollateralisation and funded reserved accounts in C 14.01

Under framework v3.2, which column of template C 14.01 should contain the retained position of the overcollateralisation and funded reserve accounts shown in column 0254 of the COREP C 14.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6694
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/04/2023

Reporting of securitisation positions when Article 244(1), point (b), CRR is applied

It is not clear how to report in C 13.01, C 14.00 and C 14.01 the securitisation positions held when Article 244(1)(b) CRR is applied.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6693
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/04/2023

C43.00 (LR4) – Reporting of RWA for positions in CIUs

What value for RWA shall institutions report for positions in CIU considering that the look-through approach shall not be used for Leverage Ratio purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6692
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/09/2023

DPM 3.2 validation rule v11366_m for C84

This validation rule checks the following formula:   {C 84.00.z, r0120, c0030} = {C 84.00.x, r0010, c0020} * {C 84.00.w, r0220, c0040}   Our institution reports available funding for USD in datapoint in C 84.00.z, r0120, c0030}.   However our institution does not have any required stable funding for USD to be reported in datapoint {C 84.00.x, r0010, c0020}.  Therefore no USD NSFR ratio can be reported in datapoint {C 84.00.w, r0220, c0040}. Question is how to report these figures to comply to this validation rule in case no required funding and NSFR ratio for USD can be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6690
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

SFTs exposure value on template C 48.02

What exposure value should be reported for a repurchase transaction on template C48.02 where the provided security is retained on the  balance sheet?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2023_6689
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 18/04/2023

Model implementation timeline given the received permission in relation to a material change

In accordance with Article 3(5) of Delegated Regulation 529/2014, “Where competent authorities have provided their permission in relation to a material extension or change, institutions shall calculate the own funds requirements based on the approved extension or change from the date specified in the new permission which shall replace the prior one. The non-implementation on the date specified in the new permission of an extension or change for which permission from competent authorities has been given, shall require a new permission from competent authorities which shall be applied for without undue delay”. It is not clear what does “the date specified in the new permission” refer to.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2023_6688
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Period to be covered by statistics pursuant to Article 32(4) of Commission Delegated Regulation (EU) 2018/389

Which period should the statistics to be published by ASPSPs under Article 32(4) of Commission Delegated Regulation (EU) 2018/389 cover in total?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2023_6687
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023