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List of Q&A's

Derivatives reporting in stable funding

On page 9 (2.1 - 6) it is stated that the derivatives payables and receivables is to be reported according to regulatory netting rules, not accounting rules, (applicable for both categories), which means that the summation of the categories are not going to be neither the same, nor add up to the total assets. Please clarify the amount to be reported for derivatives, and how the control for templates 60 and 61 will work.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_348
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Reporting frequency for template C17.00 Op risk details

Please elaborate which reporting period that should be included in the semi-annual reporting of template C017.00. According to the Annex II, part 4.2 paragraph 119 this template summarises the information by an institution in the last year. If it should be reported with a semi-annual report, which reporting period should then be included in the reporting as per end Dec resp. end June? Possible way to read this: - The same figures should be reported twice a year (just as template C16.00 contains the same figure for four quarters in row). - Rolling 12 month reporting (i.e. as per end June is 1/7 the previous year until 30/6 the reporting year)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_285
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

January and February 2014 figures for the Q1 2014 leverage ratio reporting

Does the leverage ratio Q1 2014 reporting should include January 2014 and February 2014 data

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_266
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Group solvency template - columns 300 until 340

In order to determine the qualifying own funds for the different own funds elements (Common Equity Tier 1, Additional Tier 1 and Tier 2 capital), according to sub 1 of Articles 84, 85, 86, 87, 89, capital requirements should be taken into account. Suppose, the qualifying own funds of a non-regulated entity within the CRR scope of consolidation should be determined. Is our interpretation correct that, given the fact that no capital requirements exists for a non-regulated entity, the outcome of the calculation of the qualifying own funds of a non-regulated entity according to Articles 84, 85, 86, 87, 89 always equal zero?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_263
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Group solvency template - columns 120, 130 and 140

Annex I of the ITS on reporting (Own funds templates) states that the figures to be reported in column 120 (Own funds) of the Group Solvency template should be equal or equivalent to the own funds reported in row 0010 of the template CA1. We conclude from that, that column 120 of the Group Solvency template should comprise all Tier 1 and Tier 2 capital of the entity the respective row refers to. From Annex I of the ITS on reporting (Own funds templates) we understand that column 130 of the Group Solvency template should reflect instruments (including related retained earnings, share premium accounts and other reserves) that are owned by persons other than the undertakings included in the CRR consolidation. From the same ITS and its reference to Article 87 (i)(b) of CRR we assume that column 140 relates to all own funds instruments of the subsidiary that are included in Common Equity Tier 1, Additional Tier1 and Tier 2 items and the related share premium accounts, the retained earnings and other reserves. We assume that the difference between the figures to be reported in column 120 and 140 of the Group Solvency template is that column 120 reflects all Tier 1 and Tier 2 capital of the entity the respective row refers to, whereas in column 140 only the part of Tier 1 and Tier 2 capital that is included in the consolidated own funds of the reporting entity, should be reported. Could EBA confirm that this assumption is correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_262
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Does the "Excess of deduction from AT1 items over AT1 Capital" used for the calculation of the 17.65% threshold include the transitional additions for grandfathered instruments and instruments issued by subsidiaries

When calculating the applicable 17.65% threshold, is the "Excess of deduction from Additional Tier 1 (AT1) items over AT1 Capital" (Article 36(1)(j)of Regulation (EU) No 575/2013 (CRR)) supposed to be adjusted for the transitional adjustments made earlier in the process for grandfathered instruments and instruments issued by subsidiaries?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_256
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

COREP templates to be submitted on a semi-annual basis.

The draft ITS (Articles 5(b), 6(b), 8(1)(b), 8(2)(b) and 12) and the CRR mention that OPR details, CR SEC details, Group Solvency and Losses on Immovable Properties templates are to be submitted on a semi annual basis. Can you confirm that the first reporting date for these templates will be 30 June 2014?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_244
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP F13.1 row 010 Loans and advances col. 050 Financial guarantees received

What is the information that should be included in this box? Is it the whole amount of financial guarantees received, or is it the value of those financial guarantees received that are related to loans and advances collateralized by immovable properties or any other in rem guarantee? In other words, if a loan has only financial guarantees, and none of those included in columns 010 - 040, shall that financial guarantee be included in row 010 & column 050?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_236
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of templates 7 and 5 - Row "On demand [call] and short notice [current account]"

We wonder about the reporting of overnight accounts and advances and on the scope of templates 5 and 7: - overnight accounts and advances with counterparties "central banks and credit institutions" are not reported on a "loans and advances" row in table 1.1 but on the rows 030 et 040 ; nevertheless, do they have to be reported in tables 5 and 7 which concern "loans and advances" ? If yes, do they have to be reported on the row "On demand [call] and short notice [current account]"? - does overnight accounts and advances with other counterparties have to be reported on the row "On demand [call] and short notice [current account]" in tables 5 and 7 ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_235
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Annex XV Validation formulae, "≡" vs "="

We would like to know what the differences are, for the validation formulae purpose, between the symbols "≡" and "=". E.g: Validation {F 20.04 , r140 , c030}≡{F 20.07 , r190 , c020} (without ID). Does this validation mean that the value of both "boxes" o "line items" is the same or, on the contrary, that the "concept" they both refer to is the same? We though it was the first option until we bumped into this question. If it were the second alternative, should it appear in the majority of validation links?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_231
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP F45.2

Row 010 "Property, plan and equipment" has been eliminated. Notwithstanding, currently the first row (Investment property) is row 020, not row 010. Hence, should the row 040 "Other assets" include the information previously contained in row 010?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_219
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Annex III F20.4 row 210 Of which: Commercial immovable property

What is the information requested in this row? Does it consist of loans collateralized by commercial immovable property, similarly to row 230? Or is it made up of loans granted to acquire commercial immovable property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_216
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Financial guarantees received and other commitments received (F 09.02)

1) Could you confirm that the item "Financial guarantees received" (see F 09.02, r080 – r140, c010) includes only financial guarantees received as collateral for the institution's liabilities and for institution's financial guarantees given or other commitments given (i.e. it does not include financial guarantees received as collateral for claims/financial assets, given the fact that they are considered as part of information in template F 13.01 Breakdown of loans and advances by collateral and guarantees)? 2) Consequentially we would like to clarify the treatment of other collateral received (either from the customer or from third party) for financial guarantees given and other commitments given (from template F 09.01). Should they be also included in item "Other Commitments received" of template F 09.02 (r150 – r210, c020)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_214
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Specifying default fund contribution or risk weights in C07.00 and connection to C02.00.

First, according to column 020, default fund contributions is included in column 010 (original exposure) since it is a "of which". To get row 090 - 210 to sum up to the total exposure at row 010, the default fund contribution must then also be specified on row 090-210. Since the default fund contribution not is calculated with those fixed risk weights, on which row should the amount then be inserted? Secondly, should the amount in C07.00, c220, r010 be splitted on C02.00, row 460 and 050?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_209
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: F07.00 reporting of past due assets

How to split past due not impaired financial assets according to the number of days past due? According to the Instructions in Part 2, paragraph 48: “Assets qualify as past due when a counterparty has failed to make a payment when contractually due”. Q1: Will the whole asset/loan be qualified as past due or only its part, for which the counterparty failed to make a payment? According to the Instructions in Part 2, paragraph 48 : “The amounts of such assets shall be reported and broken down according to the number of days past due”. Q2: Should the individual financial asset/loan be split into parts according to the “age” of individual instalments or should the financial asset/loan be reported in the col. for the “oldest” past due instalment? In this case “to split” will be relevant to financial assets portfolio (= individual asset will be kept as a whole, but portfolio will be split) .

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_194
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Leverage Ratio: C45.00 (LRCalc) r010: SFTs exposure according to CRR 220

The exposure for repurchase transactions, securities or commodities lending or borrowing transactions, long settlement transactions and margin lending transactions should be calculated in accordance with Article 220 (1) to (3). Should the volatility adjustments be taken into account for the determination of the leverage ratio exposure value of exposures subject to Article 220?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_188
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: Counterparty breakdown - hospitals, schools, social secretaries

As what counterparty shall hospitals, schools and social secretaries be reported? Are there any thresholds (e.g. turnover) which when exceeded then the entity shall be reported as different counterparty (e.g. in current FINREP hospitals are treated households, when turnover exceed the limit then the hospital is reported as corporate)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_184
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

NSFR: Calculation of liablities and receivables from derivatives if there is no netting agreement

NSFR: How should the amount of liablities and receivables from derivatives be calculated if there is no netting agreement with the counterparty?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_183
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: F1.1. row 040 "other demand deposits"

On the basis of the validation rules of template F1.1, row 040 is part of the sum of row 010 'cash and cash balances at central banks'. So one can assume that row 040 'other demand deposits' are deposits with central banks. However, the guidance in annex V part 2.3 (1.1 assets - § 3) stipulates that 'other demand deposits' includes balances receivable on demand with credit institutions. This seems contradictory to us. Please can you confirm whether row 040 of template F1.1, comprises 'other demand deposits' with central banks or with credit institutions.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_180
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net

During the last update on the ITS Annex III in July 2013 the FINREP P&L template was modified by removing the line item for "Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net" (table 2 row 320 ITSoR March 2013) without any explanation. But in comparison with the published DPM in July 2013 which still contains the line item there is an inconsistency. In our opinion the line item is required to reach a consistent and meaningful P&L Statement, so that we assume that removing the line item is a mistake in the templates. If it is not an error it is necessary to give guidance on the disclosure of gains or losses on derecognition of investments in subsidiaries, joint ventures and associates.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2013_178
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014