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List of Q&A's

Reporting of bilateral bank loans and book value or emission value in template C 68.00?

In column “product name” there are two categories “Retail funding” and “Wholesale funding”. How shall bilateral bank loans without collateral be treated? Shall bilateral bank loans be reported under “unsecured wholesale funding, of which financial customer” (row 120)? In the column “total amount received”, is it the book value or the emission value that should be reported? Moreover we wonder if equity should be considered as funding?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1949
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Principles for completing template C 67.00 and C 71.00

Is the counterparty defined on a group/parent level or on a legal unit level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1732
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Exit from forbearance classification in non-performing status if forbearance measures failed.

In the bank we have a question on forbearance exit rules. While the exit from forbearance in case of upgrade from default is clearly defined, the exit from forbearance classification in case of legal proceeding seems non existing. In EBA final draft on forbearance is no clear rule on reporting of non-performing forbearance when forbearance measures failed and a court procedure, e.g. compulsory settlement, bankruptcy or foreclosure, takes place.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2015_1717
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Deduction of IRB Shortfall to Own Funds

In what cell, if any, of CA1 shall institutions deduct half of the amount of the IRB shortfall of credit risk adjustments to expected losses in T2 capital?

  • 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_1189
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Template F 40.1 c095

What should be reported in template 40.1 c 095 "sector of investee"? The designation "sector" is misleading. The explaintation of the column ITS part 2.124 (h) refer to ITS part 1.25: “Sector of investee” means the sector of counterparty as defined in paragraph 25 of Part 1. But the ITS part 1.25 has no relation to template 40.1. The ITS part 1.23 explains that Financial assets shall be distributed among the following classes of instruments: “Cash on hand”, “Derivatives”, “Equity instruments”, “Debt securities”, and “Loan and advances”. Is this a wrong referencing? What should be reported in this column? 1) Should be reported the counterparty, which is described in ITS part 1.35? If yes than in our opinion the counterparty Central banks, General governments and Households must be excluded? 2) Should the sector / branch of the entity be reported in this column? If yes what is the difference between 095 and column 100 "Nace Code"?

  • 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_1152
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

FINREP F 40.2

In the Q&A 2013_93 und 2013_344 you have published clarification regarding the requirements of table 40.2. You stated that all securities issued by an entity included in the accounting scope of the group which holds the securities in their individual balance sheet, shall be reported. Table F 40.02 is to be viewed from the point of view of the entity holding the equity instruments that are included in the accounting scope of consolidation (i.e. subsidiaries, joint ventures and associates). Shall this table comprise only investments/securities that are hold by more than one holding company (Option 1) or each investments / security within the accounting scope of consolidation (Option 2). Thus is the base of investments / securities equal to table 40.1? Please see the example in the excel-sheet.

  • 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_1130
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Difference between the two references in Articles 23(1)(d) and 19(5)(b)

Could you please provide additional clarifications on why there is a difference between the two references mentioned below (between Article 23(1)(d) and 19(5)(b)) and also on what is meant by “form of security” in Article 23 (1)(d)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2582
  • Topic: Intra-group financial support
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Interpretation of Article 19(2)

Chapter III of Directive 2014/59/EU (BRRD) does not apply to intra-group financial arrangements including funding arrangements and the operation of centralised funding arrangements provided that none of the parties to such arrangements meets the conditions for early intervention. In our opinion this means that in the moment when one member of centralised funding arrangement meets conditions for early intervention the Chapter III of Title II (i.e. the chapter which regulates Intra Group Financial Support) starts to apply to the centralised funding arrangement. From that moment providing any intragroup financing to the member which meets the conditions for early intervention is only possible if, inter alia: - • conditions set by Article 23 BRRD are met and • providing of such financing is notified to the supervisory authority and approved by that authority as required by Article 25 BRRD. Is our understanding correct?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2581
  • Topic: Intra-group financial support
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Amendments to Article 19

Could you please clarify Article 19(1) and (2) of Directive 2014/59/EU (BRRD)? The words “that meets the conditions for early intervention pursuant to Article 27” in Article 19(1) were added to the original draft of the BRRD), in addition to the insertion of Article 19 (2), which provides that the Intra Group Financial Support (IGFS) chapter does not apply if ”none of the parties” meets the conditions of early intervention. The addition to the original draft refers to “arrangements” rather than “agreements”. We understand “arrangements” to be broader, and to refer to arrangements of any kind. Only a subset of these, called ”group financial support agreements” are regulated by the BRRD. Does this variation in terminology affect implementation?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2579
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Intra-group financial support consideration

According to Article 23 Directive 2014/59/EU (BRRD), the intra-group financial support may be granted if there is a reasonably prospect that the beneficiary party pay the consideration. Should this consideration only take a pecuniary form?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2563
  • Topic: Intra-group financial support
  • Date of submission:
  • Published as final Q&A: 05/02/2016

F 46.00 - changes in equity - other equity and total comprehensive income

Cell r200-c040 is marked as grey in FINREP table 46 and consequently this cell is not to be filled in. However, if a financial institution has classified "Total comprehensive income" in changes in equity under "Other equity" in its financial reporting based on IFRS, where are we to put this number?

  • 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_1123
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Annex V - FINREP - Table 31.1 Related parties

In Annex V it is stated in paragraph 120 that "institutions shall include the portions of balances and transactions with joint ventures and associates of the group to which the entity belongs that have not been eliminated when either proportional consolidation or the equity method is applied." If a financial institution uses equity method for consolidation purposes for assiciates of the group, does this mean that column 030 in table F 31.01 is to be left empty?

  • 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_1122
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Predetermined amount in case of applications for redemptions, reductions and repurchases by mutuals, cooperative societies, savings institutions or similar institutions for the purposes of Article 77 CRR

Article 32(2) of Commission Delegated Regulation (EU) No 241/2014 (RTS on own funds) states: “Competent authorities may give their permission in advance to an action listed in Article 77 of Regulation (EU) No 575/2013 (CRR) for a certain predetermined amount to be redeemed, net of the amount of the subscription of new paid in Common Equity Tier 1 instruments during a period up to one year. That predetermined amount may go up to 2 % of Common Equity Tier 1 capital […]”. 1. Which of the following interpretations is correct? (1) Once permission is given for a certain predetermined amount, any subsequent subscription of new paid-in CET1 instruments during a period up to one year from date of permission increases automatically the total amount that is permitted to be redeemed (i.e. the maximum redemption amount that can be permitted in advance is 2% + x, for which x increases with any amount of new paid-in CET1 instrument additionally subscribed within one year). (2) In addition to the predetermined amount, the advance permission covers solely the amount of subscriptions during the period of one year that are already expected at the moment the permission is granted, i.e. it solely extends the predetermined amount by a fixed amount for the issuances already planned at the moment the permission is granted. (3) The advance permission for redeeming the predetermined amount does not cover redemption of new paid-in Common Equity Tier 1 instruments during a period up to one year. 2. Could it be that, because of an editorial oversight, a comma is missing in the first sentence of Article 32(2) RTS on own funds, before "during a period up to one year"? Setting the comma would consistently restrict not only the recognition of new subscriptions but already the advance permission for redemption to the same period of one year.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2015_2094
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Predetermined amount for market making with partially grandfathered or amortised instruments

An institution has asked for advance permission according to Article 78(1) last subparagraph Regulation (EU) No 575/2013 (CRR) to carry out repurchases of its own funds instruments for market making purposes. It intends to repurchase up to 3% of the nominal amount of these instruments. Some of these instruments are partially phased-out ('grandfathered' instruments) or already partially amortised. 1. What is in this case the predetermined amount for the limits in Article 78(1) last subparagraph CRR which is, according to Q&A 2014_1352 [as originally published on 8 July 2014] , required to be deducted pursuant to Article 28(2) of Delegated Regulation (EU) No 241/2014 from the moment the authorisation is granted?(a) 3% of the nominal amount of the instruments (i.e. including phased-out/amortised amounts), or(b) solely 3% of the amount still qualified for own funds (i.e. excluding phased-out/amortised amounts) 2. Do in this case the amounts of the relevant issuance and of total outstanding Additional Tier 1 instruments or Tier 2 instruments refer to(a) the full nominal amount (i.e. including phased-out/amortised amounts), or(b) solely the amount still qualified for own funds (i.e. excluding phased-out/amortised amounts)? 3. If solely the amount still qualified for own funds is considered for the predetermined amount or the limits, what is the maximum amount that the institution can repurchase?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2015_2095
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Values pre or post conversion factors

Should institutions report in C 07.00 columns 160-190 a) the amounts of column 150 allocated to each conversion factor after or before the application of conversion factors?

  • 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: 2015_1884
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Country breakdown

On which country codification exposure relative to Kosovo may be valuated for the various CO-FINREP Reporting?

  • 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: 2015_1710
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Definition of "Other collateralized loans" in relation to validation rules between F 05.00 (r100) and F 13.01 (c030, c040)

Do credit institutions in row "of which: other collateralized loans" in the tables F 05.00 and F 07.00 include also loans and advances that are secured by received financial guarantees or other guarantees? Final draft ITS on supervisory requirements in Annex V, Part 2.41 (i) for Tables F 5.00 states: “Other collateralized loans” include loans formally backed by collateral, independently of their loan/collateral ratio (so-called “loan-to-value”), other than “Loans collateralised by immovable property”, “Finance leases” and “Reverse repurchase loans”. This collateral includes pledges of securities, cash, and other collateral."

  • 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_1309
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

FINREP: Definition of „Non-Financial Corporations” in Template 6 – Breakdown of loans and advances to non-financial corporations by NACE code

Should this table include deals with non-financial corporation as defined in Annex V, Part 1, Paragraph 35 (e) or all deals with counterparties with their core business in non-financial sectors (e.g. also including general governments and households as defined in Annex V, Part 1, Paragraph 35 (b) & (f))?

  • 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_1237
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Template C09.03 (CR GB3) - Breakdown of total own funds requirements for credit risk of relevant credit exposures by country.

Template C09.03 (CR GB3) column 010; is the requirement to report risk weighted assets (RWAs) or Capital Requirement (RWAs x 8%)?

  • 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_1186
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Validations between F 13.01 and F 05

According to the Final Q&A 2013_512 (posted on 21/03/2014), “the amounts to be reported in templates F 05.00 and F 13.01 diverge. Within F 05.00, the outstanding amount of the loans shall be reported, while in F 13.01, it is the amount of the collateral that shall be declared capped by the amount of the loan”. “(…) That means that the validation rule v1074_m shall be expressed with the sign “<=”, that is, sum({F 13.01, r010, (c010-020)}) <= sum({F 05.00, r090, (c020-060)}”. We understand that if validation rule v1074_m is corrected, other validations that relate templates F13.01 and F05 with the sign“=” should be also modified. Would it be also necessary to correct the sign “=” on validations that are listed below? v1076_m v1077_m v1079_m v1080_m v1082_m v1083_m v1085_m (See example of validations v1076_m or v1077_m in attached document)

  • 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_1141
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/01/2016