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  1. Home
  2. Single Rulebook Q&A
  3. 2022_6607 Netting for Asset Encombrance
Question ID
2022_6607
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Asset Encumbrance
Article
430
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 โ€“ ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
ANNEX XVII, part 1, point 1.2
Type of submitter
Credit institution
Subject matter
Netting for Asset Encombrance
Question

In the context of the assets encumbrance, are we supposed to match the netted amount carried out in the FINREP reporting (according accounting standards)?

Background on the question

As part of the production of FINREP reporting in the IFRS phase, pensions have been netted in accordance with IAS 32, which requires the following two conditions:

1. Legal right to offset. 
The entity currently has a legally enforceable right to offset amounts recognized on its balance sheet. An entity has an unconditional, legally enforceable right to set off assets and liabilities, if that right (IAS 32.42a and .AG38B s.):
- does not depend on the occurrence of a future event; and- exists in the course of its normal activity and also in the event of default, insolvency or bankruptcy.

2. Intention to offset.
The entity intends to offset future cash flows (IAS 32.42b and .AG38E s.):
- either by settling only their net amount; - or by realizing (collecting) the assets and settling the liabilities simultaneously.

However, according to COMMISSION IMPLEMENTING REGULATION (EU) 2021/451 of 17 December 2020, ANNEX XVII, part 1, point 1.2 at the level of the assets encumbered , the institutions must declare the gross book values โ€‹โ€‹of compensation
"In AE-SOU, institutions shall generally report carrying amounts gross of accouting netting"

We have been following this rule to the level of assets encumbered .

These differences in treatment have therefore created a discrepancy between the FINREP (total assets) and the assets encumbered  (total assets) not respecting the validation rule
v2814_m: sum({F 32.01, r0010, (c0010, c0060)}) = {F 01.01, r0380,c0010}

Please tell us if we have to comply with the general rule mentioned in the Implementing Regulation 2021/451 (with carrying amounts gross of accounting netting in AE reportings), or if we have to comply with Validation Rule v2814 and match the assets encumbered with FINREP netted amounts.

Submission date
11/10/2022
Rejected publishing date
28/09/2023
Rationale for rejection

This question has been rejected because the matter it refers to has been answered in Q&A 1630.

Status
Rejected question

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