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List of Q&A's

Maturity matching

Articles 45(a), 59(a), 69(a) of Regulation (EU) No 575/2013 (CRR) each include a condition that “the maturity of the short position matches the maturity of the long position or has a residual maturity of at least one year”, in order for the short position to be recognized for the calculation of the net long position. Please confirm that maturities are deemed to match for the purposes of these provisions where the maturity of the short position is greater than the maturity of the long position. Where the maturity of the short is greater than the maturity of the long the institution will only ever be left with a net short position (economically a forward starting short), all things being equal, and should not therefore have to take a deduction.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_252
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 10/10/2014

Definition of independent valuer referred to in Article 229(1) of Regulation (EU) No 575/2013 (CRR)

1. What is a definition of independent valuer referred to in Article 229(1)? 2. Whether the definition of independent valuer referred to in Article 229(1) is specified in Article 208(3)(b)? 3. Whether independent valuer is defined as a person who possesses the necessary qualifications, ability and experience to execute a valuation and who is independent from the credit decision process? 4. Whether the Regulation (EU) No 575/2013 (CRR) imposes additional obligations than those indicated in Article 208(3)(b) on a person who execute valuation as independent valuer? 5. Whether an independent valuer referred to in Article 229(1) may be an employee of the bank? 6. Whether CRR excludes the possibility of valuing the property for the purposes of Article 229(1) by employees of the bank?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1056
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Treatment of recognised exchanges (non-third country vs. third country)

Are exchanges, explicitly exchanges according to Article 4(1)(72) of Regulation (EU) No 575/2013 (CRR), also treated like institutions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_677
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Substitution of ratings for CRMT purposes

For the instruments listed in Article 197 of Regulation (EU) No. 575/2013 (CRR), is it possible to use the issuer rating in order to derive eligibility (and haircuts) where no specific instrument rating exists (“substitution”)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_679
  • Topic: External Credit Assessment Institutions (ECAI)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Relevance of Issuers Rating for Article 120 of Regulation (EU) No 575/2013 (CRR)

Does Article 120 of Regulation (EU) No 575/2013 (CRR) refer to claims only, where there is an issue-related rating existing, or does it also cover claims, where no rating exists for the issue, but for the issuer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_652
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Content of “accumulated changes in fair value due to credit risk” in template F 16.05

Column 020 of template F 16.05 is labeled as “Accumulated changes in fair value due to credit risk”, whereas the respective instructions (paragraph 100 of part 2 of Annex V of the ITS on supervisory reporting) reads “Institutions shall report the net realised and unrealised and the amount of change in fair value in the period due to changes in the credit risk (own credit risk of the borrower or issuer).”. We would like to get confirmation that the instructions shall be followed and that the use of the word “accumulated” in the second column of F 16.05 is a typo.

  • 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: 2014_1109
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Annex II and VIII of the ITS on supervisory reporting under the CRR

According to the Article 395 paragraph (5) point a) of CRR the limit to large exposure may be exceeded for the exposures on the institution's trading book – among others - if the exposures on the non-trading book do not exceed the limit laid down in paragraph (1). How shall the excess of limit to the large exposure on the non-trading book after CRM be reported in the CA2 template?

  • 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: 2014_1085
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Definition of non-financial corporate credit and liquidity facilities.

Please could you clarify the definition of facilities offered to non-financial corporates to be reported in rows 1230 and 1240 of template 52?

  • 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: 2014_979
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Missing activity in NACE code - for agiculure

Dear Sir/Madam! We found out that there is no NACE code in ITS for activity Agriculture. In NACE code are for eg. codes A - Agriculture, forestry and fishing, A2 - Forestry and logging and A3 - Fishing and aquaculture. But there is not code for Agriculture, which could be A1. That you for your answer. Best regards, Tjaša Češnovar BANKA SLOVENIJE Eurosystem Banking supervision Slovenska 35 1505 Ljubljana Phone: +386 1 47 19 341 Faks: +386 1 47 19 727 E-mail: Tjasa.Cesnovar@bsi.si Website: http://www.bsi.si

  • 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: 2014_976
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 03/10/2014

LCR Sign Convention

What sign convention has to be applied for outflows? Should they be reported as positive or negative figures?

  • 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: 2014_971
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

F 31.01

Annex XV_Validation formulae with IDs v1030_m, v1031_m, v1032_m, v1034_m, and v1036_m define that the sum of outstanding balances in F31.01 should be equal or less than the balances reported in corresponding rows of other FINREP tables (F 07.00, F 43.00, F 08.01.a in F 09.00) less balances with counterparties from sectors »Central banks« and »General government«. Does that mean that these sectors cannot be reported as related parties? Taking into account the fact that all data in columns of template F31.01 refers to IAS 24.19, could it be assumed that also transactions with other counterparties related to the state (IAS 24.25 in 24.26) are not considered in the template? In case the bank is state-owned these validation rules would not hold out.

  • 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: 2014_915
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

C 14.00 – DETAILED INFORMATION ON SECURITISATIONS (SEC DETAILS) - FIELD 290

Field 290 - First Foreseeable Termination Date. Firstly, if there is no call date and the clean-up date is not known (e.g. for an Investor position), what do we report here? Secondly, if there is a call date but this is now in the past (i.e. hasn't yet been called) what do we report here?

  • 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: 2014_913
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

C 14.00 – DETAILED INFORMATION ON SECURITISATIONS (SEC DETAILS) - FIELD 080

Field 080 - Type of Retention Applied. How do we report for Investor positions? Information is not publicly available.

  • 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: 2014_901
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Exit criteria for performing exposure under probation that has been reclassifiied to non-performing because it has been re-forborne or is more than 30 days past-due

According to paragraph 180 non-performing exposures with forbearance measures comprise forborne exposures that meet the criteria to be considered as non-performing. These exposures are forborne exposures which have been reclassified from the performing category, including exposures under probation having been re-forborne or more than 30 days past-due. However, which exit criteria does apply to cease being non-performing for this specific non-performing exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_886
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Forbearance - Arrangement to Pay and Promise to Pay

The question concerns the identification of forbearance measures, namely the ‘Arrangement to Pay’ and the ‘Promise to Pay’. With this question I want to propose that an Arrangement to Pay will not be classified as forbearance. I would like to know whether you agree on my conclusion. Forbearance (EBA definition) Debts with forbearance measures are contracts / the terms (1) of which the debtor is considered unable to comply with (2) due to its financial difficulties so that the institution decides (3) either to modify the terms and conditions of the contract to enable the debtor to service the debt or to refinance, totally or partially, the contract. When determining whether a measure constitutes as forbearance the following aspects should be taken into account: A. Is the counterparty in financial difficulties? B. Is there a modification of the terms and conditions of the contract? C. Is the modification a concession? D. Is the classification of forbearance aligned with the objectives of the regulator?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2013_654
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

v0679_m: taxonomy is incorrect.

The validation rule for the RWA of the off-balance sheet items (C43.00 r010, c020) only considers the RWA of the off-balance sheet items subject to credit risk in Total-Standard approach (C 07.00a r080, c220, s001) and the RWA of the off-balance sheet items subject to credit risk in Total-IRB Approach to capital requirement with own estimates of LGD and/or conversion factors (C 08.01a r030, c260, s001). Should the RWA of the off-balance sheet items subject to credit risk in Total-IRB Approach to capital requirement without own estimates of LGD and/or conversion factors (C 08.01a r030, c260, s002) also be considered in this validation rule?

  • 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: 2014_1251
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Treatment of Croatian currency - Kuna (HRK) and Croatian national market in Market risk reporting templates

We have noticed that there is no code for Croatian currency (HRK) as pre-defined separate reporting currency in templates C18 and C22 and no code for Croatian market as pre-defined separate reporting market in template C21.

  • 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: 2014_1370
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Lines 290 to 320 of the CR SA’ state

1/ For lines 290 and 310, are the columns "215" and "220" matching the exposures’ weighted amounts if they were not secured by a mortgage or is it necessary to declare the same weighted amounts shown in line 010 classified according to the category of the exposure’s original counterpart. 2/ For lines 300 and 320, is the column "215" matching the exposures’ weighted amounts if they were not in default or is it necessary to declare the same weighted amounts shown in line 010 classified according to the category of the exposure’s original counterpart. 3/ Lines 300 and 320 of the CR SA’ state concern defaulted exposures for which categories before being in default were as such: - Central governments and central banks - Regional and local administrations - Public Sector Entities - Institutions that are not subjected to an evaluation of short-term credit - Businesses/Corporates that are not the subjected to an evaluation of short-term credit - Retail (customers ) Can you confirm that defaulted exposures secured by a mortgage are not affected by lines 300 and 320 of the CR SA state? However, they will be reported in the column "020" of the line 90 of the CR GB 1 state.

  • 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: 2014_1163
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Different ID

Why "Public sector entities" dimension in the table C 07.00 does not have same type of linking to the table C 02.00 as does have for example "Regional governments or local authorities" dimension?

  • 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: 2014_1090
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014