Question ID
2024_7258
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
11
Type of submitter
Consultancy firm
Subject matter
Equity instrument subject to impairment in F20.04
Question

The instructions for reporting the column "of which: financial assets subject to impairment [...]" regarding equity instruments (see F20.04 r0040 c0012) currently leave room for interpretation about the specific definition of "subject to impairment" to be applied.

In particular, we would kindly ask the EBA to clarify whether 
a) the respective positions should be deactivated (i.e., greyed out) because of non-applicability
b) there is a different expectation regarding equity instruments that has not been written in the Annex yet (in particular, equity instruments are subject to the IAS 36 impairment test).

Background on the question

It is unclear which information has to be reported  regarding equity instruments subject to impairment in template F20.04 r0040 c0012 (et seqq). The reference provided in the template ("Annex V.Part 2.273") states that financial assets subject to impairment shall have the same meaning as defined in Annex V.Part 2.93. However, paragraph 93 refers to financial assets at AC and at FVtOCI only, which is in line with IFRS 9 impairment requirements. That being said, regarding equity instruments there is no such requirement.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the objective of the Q&A tool is not to change the current supervisory regulatory framework. However, the proposed suggestion will be taken into account in a future release of the supervisory reporting framework.

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. For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'. 

Status
Rejected question