- Question ID
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2024_7059
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
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Article 467/468
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
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Not applicable
- Type of submitter
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Credit institution
- Subject matter
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Fair-valued assets and liabilities excluded because of partial impact on CET1 – Prudential Filters
- Question
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Template C32.01 Prudent valuation. Fair-Valued assets and liabilities requires the Prudential filters Fair-valued assets and liabilities excluded because of partial impact on CET1 (col 0050) to be reported in accordance with Article 4(2) of Delegated Regulation (EU) 2016/101 due to the transitional application of the prudential filters referred to in Articles 467 and 468 of Regulation (EU) No 575/2013. Since Articles 467 and 468 of Regulation (EU) No 575/2013 are related to COVID transitional fix items, should the institution report 0 in this column until the guidance is updated? Additionally, validation v6566 related to this template, states that values reported for Fair-valued assets and liabilities excluded because of partial impact on CET1 – Prudential Filters (c0050) have to be equal to or higher than 0. Could you please confirm if this validation is applicable in all the contra liability balances?
- Background on the question
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Template C 32.01 Prudent valuation. Fair-Valued assets and liabilities requires the Prudential filters Fair-valued assets and liabilities excluded because of partial impact on CET1 (col 0050) to be reported in accordance with Article 4(2) of Delegated Regulation (EU) 2016/101 due to the transitional application of the prudential filters referred to in Articles 467 and 468 of Regulation (EU) No 575/2013. However, Articles 467 and 468 of Regulation (EU) No 575/2013 are no longer relevant as they are related to COVID transitional fix items implying 0 amount to be reported. However, we believe this would not reflect the accurate balances for the FV in col 0050. Specifically, the amount of the prudential filters for DVA (changes in the value of fair valued derivative liabilities due to changes in credit standing). Changes in the accounting value of DVA has a zero impact on CET1 and is excluded from the calculation of fair valued assets and liabilities for the purposes of Article 4 of Delegated Regulation (EU) 2016/101. In terms of the balance sheet geography of DVA, it is a contra liability (i.e., an amount reported in financial liabilities held for trading that reduces the value of liabilities). Therefore, the impact of excluding this amount from financial liabilities held for trading results in a larger amount of liabilities. These liabilities would be reported as a negative balances in col 0050. However, current Validation v6566 requires balances reported for the FV PruVal (col 0050) to be equal to or higher than 0. This would indicate it is incorrect to report the amount as a negative amount in column 0050 of the C32.01 template. Could you please advise if above described contra liability balances should be reported in col 0050 in the Template C 32.01.
- Submission date
- Rejected publishing date
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- Rationale for rejection
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This question has been rejected because the matter it refers to has been answered in Q&A 1715. Additionally, the issue of the reference to Article 33 CRR has already been identified and will be considered for a forthcoming versions of the Reporting framework.
- Status
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Rejected question