- Question ID
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2025_7365
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Supervisory reporting - FINREP (incl. FB&NPE)
- Article
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430
- Paragraph
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3
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
- Article/Paragraph
-
11 / Section 2 to Annex I
- Type of submitter
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Credit institution
- Subject matter
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Table F12.01 – Movements in allowance and provisions for credit losses
- Question
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Considering the greyed out columns in row 350 and 550: How can the actual movement of impairment be reflected correctly?
- Background on the question
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For row 550 (Commitments and financial guarantees given (Stage 2): of which: non-performing exposures) and row 350 (Allowances for debt instruments with significant increase in credit risk since initial recognition but not credit-impaired (Stage 2) of which: non-performing exposures) several columns are greyed out. For row 550 even column 40 (Changes due to change in credit risk (net)) is blocked (which is not the case for row 350).
The only columns that are not blocked for row 550 are column 50 (Changes due to modifications without derecognition) and column 80 (Decreases in allowance account due to write-offs), which are in our opinion not enough to describe the detailed movement in this row.
We think that greying out some of the fields is not correct, because one cannot reflect the actual movement of impairment correctly and the template must be corrected accordingly.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the objective of the Q&A tool is not to answer questions that put into doubt the correctness of the legal framework or try to lobby for a modification of the text. 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
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Rejected question