Question ID
2024_7227
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
Paragraph
ANNEX XXXIX - Template 8
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
Article/Paragraph
18a
Type of submitter
Competent authority
Subject matter
Calculation of GAR - Template 8 of ESG Templates Pillar 3
Question

How should we correctly compute the GAR (%) stock and flow?

Background on the question

We would like to clarify our understanding regarding Template 8 of ESG Templates Pillar 3.

  1. We assumed that {D 08.00, r0010, c0010} = {D07.00,r0320,c0020} / {D 07.00, r0450, c0010}. However, for the subsequent rows, we are uncertain whether the denominator remains the total gross carrying amount of “Total assets in the denominator (GAR)” or if it should be the corresponding row segment.

    For example, should {D 08.00, r0020, c0010} be {D07.00,r0010,c0020} / {D 07.00, r0010, c0010} or {D07.00,r0010,c0020} / {D 07.00, r0450, c0010}?

  2. Regarding the flow calculation, we are uncertain about the correct method. We assumed it to be:

    {D 08.00, r0010, c0170} = nominator/ denominator, with nominator and denominator being,

    nominator = {D07.00,r0320,c0020}year ref date -  {D07.00,r0320,c0020}year ref date - 1

    denominator = {D 07.00, r0450, c0010}year ref date 

    By considering this formula, some results can have negative values, contradicting EBA's validation rule v12841_s. Could you please confirm if our interpretation of how to compute these values is correct? If it is not, could you clarify the correct method of calculation?

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is already explained in the instructions for Template 8 of Annex XL of Regulation (EU) 2021/637.

Regarding point 1 raised, following the example provided, institutions should follow the below formula how to calculate the GAR (%) stock values:

{D 08.00, r0020, c0010} = {D07.00, r0010, c0020} / {D 07.00, r0010, c0010} 

{D 08.00, r0030, c0010} = {D07.00, r0020, c0020} / {D 07.00, r0020, c0010} 

{D 08.00, r0040, c0010} = {D07.00, r0030, c0020} / {D 07.00, r0030, c0010} 

…

The instructions for rows 2 to 16 for Template 8 specify which rows to use for the calculations from Template 7 of the same Annex XL of Regulation (EU) 2021/637.

Regarding point 2 raised, this has been already explained in Q&A 2024_7082, as both the nominator and the denominator should be calculated as […the gross carrying amount of eligible new assets…] and [… the gross carrying amount of new covered assets…] respectively. The amount of new assets could be either 0 or a positive value, therefore validation rule v12841_s is correct expecting non-negative values in those cells this validation rule is covering.

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Status
Rejected question