Question ID
2026_7807
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex V
Type of submitter
Credit institution
Subject matter
Clarification on validation v3078m under FINREP reporting
Question

In reference to the validation rule 'v3078_m' should the held for trading positions be excluded while reporting the maximum amount of the guarantee received in FINREP F_09.02

Background on the question

Validation v3078_m compares the values in F_09.02 (r080, c010) with F_18.00.C (c205, c210, r330, r550). And, in F_18.00.C we are expected to report guarantees received on 'Debt Instruments other than held for trading or trading'. This means that guarantees received on held for trading exposure should not be reported in F_18.00.C. Since the validation rule is comparing F_09.02 with F_18.00.C, is it fair to assume that even while reporting the guarantee received in FINREP F_09.02, the guarantees received on held for trading exposure be excluded? 

Submission date
Final publishing date
Final answer

In Finrep template F 18.00 ‘Information on performing and non-performing exposures’, the financial guarantees received on 'debt Instruments held for trading or trading' are not reported. This does not imply that these financial guarantees received should also be excluded from the reporting in template F 09.02. The instructions to the latter (IT solutions – Annex V to Commission implementing regulation (EU) 2024/3117, Part 2, par 102 and 119) do not explicitly exclude the financial guarantees received on 'debt Instruments held for trading or trading' and the validation rule v3078_m compares the values in F_09.02 (r080, c010) with the ones F_18.00.C (c205, c210, r330, r550) but does not express an exact equivalence between them (xsum({F 18.00.c, (c0205, c0210, r0330, r0550)}) <= {F 09.02, r0080, c0010}). This rule will be satisfied even in case of existence of financial guarantees received on debt instruments held for trading or trading.

For additional clarification regarding the “maximum amount of the guarantee that can be considered” under validation v3078_m in templates F 18.00.c and F 09.02, QA 2020_5634 should be taken into account.

Status
Final Q&A

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