Question ID
2022_6520
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
4
Paragraph
1
Subparagraph
77
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Template 46
Type of submitter
Individual
Subject matter
F 46 EBA_v1226
Question

How to match the re-translated opening balance (in current year) with closing balance (from prior year) on F 46 when the constant USD value is being converted to EURO in two different reporting periods with different FX rate? If the same prior year converted value in EURO is stated in opening balance (before restatement row 10), then how and which row does the FX translation impact shall be reflected?

 

Background on the question

On Template 46, opening balance (current period - row30) and opening balance (before restatement row 10) never matches the prior year due to the functional currency is anchored in USD in the entity's Financial Statement which is converted to EUR only for FINREP Reporting purposes in Template 46 at the reporting date’s fx rate. This means that although the USD numbers as per the financial statements (closing of prior year and opening balance of the current year) does not change, but the equivalent EUR converted figures changes due to the different exchange rate at two different reporting periods. 

 

ECB requested to open a Q&A to receive the accurate guidance on how to address the issue.

 

Submission date
Final publishing date
Final answer

In template F 46.00, opening balance (before restatement row 0010) shall match the prior period closing balance.

Any foreign exchange difference cannot be considered as an “error” or a “change in the accounting policies” as per the definitions of accounting standards. Therefore, rows 0020 or 0030 of template F46 should not be used. Instead, it should be considered as a movement of the year and reported in one of the rows from 0050 to 0200, depending on the items. 

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

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