Question ID
2018_3792
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
NA
Type of submitter
Credit institution
Subject matter
Validation rules on template F 18.00 comparing with F 04.04.1 and F 01.01
Question

In the validation rules v2776_m the balance from F01.01 row 040 Other demand deposits is added. In the validation rules v3028_m/v3031_m/v3035_m row 040 Other demand deposits is not added. In these validation rules the Impaired amounts in template F 18.00a are compared to the Stage 3 amounts in template F 04.04.1 (excluding 040 other demand deposits). Is this correct?

Background on the question

The validation rules in question are: v2774_m: {F 18.00.a, r080, c010} = sum({F 04.04.1, r080, (c015, c030, c040)}) + {F 01.01, r030, c010} v2776_m: {F 18.00.a, r100, c010} = sum({F 04.04.1, r100, (c015, c030, c040)}) + {F 01.01, r040, c010} v3028_m: {F 18.00.a, r070, c120} = {F 04.04.1, r070, c040} v3031_m: {F 18.00.a, r100, c120} = {F 04.04.1, r100, c040} v3035_m: {F 18.00.a, r180, c120} = {F 04.04.1, r140, c040} The first 2 validation rules state that you have to make sure that the amounts in row 030 Cash balances at central banks and row 040 Other demand deposits in template F 01.01 are included in template F 18.00 - Information on performing and non-performing exposures. However, in the last 3 validation rules there is no reference to the amounts reported on the rows 030 and 040 in template F 01.01. Shouldn’t these amounts also be included on the line items in template F 18.00?

Submission date
Final publishing date
Final answer

According to Part 2, paragraph 217 of Annex V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), template F 18.00 of Annexes III and IV to the ITS on Supervisory Reporting covers also cash balances at central banks and other demand deposits. However, template F 04.04.1 does not include cash balances at central banks and other demand deposits. Hence, if those items where impaired, validation rules validation rules v3028_m, v3031_m, v3035_m may not hold.  The same applies to validation rule v3029_m. Therefore, the rules are non-blocking.

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

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