Question ID
2024_7156
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Funding Plans
Article
Part II
Paragraph
2.2
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EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05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
Type of submitter
Credit institution
Subject matter
Failed rule EGDQ_0875 – proposed check on 12/2023 FP
Question

How to cope with the issue described below for the future EBA Funding Plan deliveries avoiding any “failed” rule?  

Background on the question

The validation rule “EGDQ_0875” has been implemented as a proposed check for EBA Funding Plan 2023 for the first time and referring to the EBA Funding Plan template “P_01_01_Asset balance”. The description of this rule is as follows: 

“If geographical breakdown is reported in FINREP, the domestic loans and advances to households and corporations, other loans and advances and reverse repurchase loans ({r020+r040+r110+r181+r191+r195+r197,c010}) are expected to be more than the domestic loans and advances in FINREP ({F20.01,r0090+r0095+r0099+r0130+r0144+r0174+r0178+r0183+r0233+r0237,c0010})”

In our point of view this validation rule leads to an error since the volumes of “counterparty split (e.g. row codes 030, 100, 180, …..)”, which is the supercategory of geographical breakdown, come from another FinRep table  F05.01. The problem we see is, that the “Loan and advances” definition of F05.01 (counterparty split) is different to F20.01 (geographical breakdown). The table F05.01 includes the position “other demand deposits” and excludes the position “trading loans and advances” while in F20.01 it is vice versa. Due to different “loans and advances” definition the volume can’t match and thus rule will lead to an error.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. 

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Status
Rejected question