Question ID
2014_1031
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph
Annex V.Part 2.157, Annex V.Part 2.172(a), Annex V.Part 2.180
Name of institution / submitter
KPMG
Country of incorporation / residence
UK
Type of submitter
Consultancy firm
Subject matter
Forborne exposures, Template 19, column 110
Question

Column 110 of Template 19 provides references to Annex V.Part 2.157 and Annex V.Part 2.172(a). Our understanding is that this column requires disclosure of exposures with forbearance measures, that would otherwise be classified as performing but have not met all of the additional exit criteria extended to non-performing exposures with forbearance measures as defined in Annex V.Part 2.157 (e.g., the exposure is no longer classified as defaulted or impaired and there are no past due amounts, but only 8 months have passed since forbearance measures were extended and therefore it should remain to be classified as non-performing). We believe that the intent is to show those exposures that are performing better after the forbearance measures were extended and would be classified as performing if there were no additional exit criteria set out by Annex V.Part 2.157. Can you please confirm if this is a valid interpretation or different information is required to be reported in this column?

Background on the question

Column 110 “of which: forbearance of non-performing exposures” of Template 19 is a subset of Column 60 “non-performing exposures with forbearance measures”. References provided for this column refer to Annex V.Part 2.157 that set out conditions when non-performing exposures to which forbearance measures were extended may be considered to have ceased being non-performing and Annex V.Part 2.172(a) that states that the situation when “a modified contract was classified as non-performing or would in the absence of modification be classified as non-performing“ shall be treated as forbearance measure. Furthermore, Annex V.Part 2.180 states that “Exposures to which paragraph 157 applies shall be separately identified in the column “of which: forbearance of non-performing exposures”.

Submission date
Final publishing date
Final answer

In accordance with paragraph 180 of Annex V of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS), column 110 of F 19.00 Template shall contain data about exposures that were non-performing prior to the extension of forbearance measures and which are still non-performing at the reporting date according to paragraph 157.

In contrast, column 60 of F 19.00 Template ("Non-performing exposures with forbearance measures") shall include all non-performing exposures with forbearance measures as defined in paragraph 180.

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

Disclaimer

The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.