Question ID
2024_7133
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Funding Plans
Article
Not applicable
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
Article/Paragraph
Annex 1 - Paragraph 2.3 (P01.02)
Type of submitter
Credit institution
Subject matter
Funding plan - validation rule EBA_v08992
Question

How can we solve a breach in the v08992_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities  to be declared in P01.02 in line r140 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

Background on the question

It seems there are discrepancies between the Taxonomy/DPM published and the validation rules implemented. See file "DPM table layout and data point categorisation [ZIP, 8027 KB]" published for the Reporting Framework 3.2 on the EBA website : https://www.eba.europa.eu/risk-and-data-analysis/reporting-frameworks/reporting-framework-32 / https://www.eba.europa.eu/sites/default/files/2023-11/7e727bbe-83e4-4faa-938e-7580a29d5482/3.2%20table%20layouts.zip. In the published EBA taxonomy (Reporting framework 3.2), the accounting dimension code (APL:PL)  in the column M of the Annotated table layout 321-P2-FP 3.2.1 excel file for P01.02 row 140 is (PL:x74) = Accounting portfolios for financial liabilities OTHER THAN CLASSIFIED AS HELD FOR SALE, provoking a breach with EBA validation rule v08992_m.

Indeed, v08992 compares {P01.02,r140,c010} and {F08.01.a,r0220+r0230+r0240,c0010+c0020+c0030+c0034+c0035}, whereas, c0010 column in F08.01 is related to assets held for sale.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because it is considered that EBA guidance or clarification is not needed with regard to the issue that it raises as it is considered that the DPM is sufficiently clear and unambiguous with regard to the relationship between different items in the modelling related to accounting portfolios items/members.

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts.

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Status
Rejected question