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List of Q&A's

Reporting of connected clients and underlying individual clients exposures and type of counterparty indication in C27

The institution has exposures to each individual member of a group of connected clients consisting of a mixed holding company (that is the parent company, in the below example 'ABC group') and a credit institution (that is a subsidiary of the parent company, in the below example 'ABC bank'). The exposure to the credit institution is the largest (approx. 90% of the exposure to the connected group). The exposures are included in the LE reporting in accordance with Annex 4 part 2 (5) (10 largest institution exposures). Can you confirm if the institution is correct to report the counterparties in C27 in the below manner? Code (010) Name (020) Lei code (030) Residence (040) Sector (050) Nace (060) Type (070) (1) Code ABC group ABC group Lei ABC group Country ABC group (empty) (empty) I (2) Code ABC group ABC group Lei ABC group Country ABC group Fin Corp K64 (empty) (3) Code ABC bank ABC bank Lei ABC bank Country ABC bank Credit Inst (empty) I First line (1) is for the indication of the parent/head of the group of connected clients, and in accordance with Annex 4 Sector (050) and Nace (060) are left empty and Type is set at 'I' (for the reference to C30 and C31). Second line (2) is for the individual exposure to ABC group, and third line (3) is for the individual exposure to ABC bank.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2020_5487
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

References for row 096 “Deferred Tax Assets subject to a risk weight of 250 %” of table c04.00 in Reg. 680/2014

Are the references included in the instructions for row 096 “Deferred Tax Assets subject to a risk weight of 250 %” of table c04.00 (Reg. 680/2014, as amended by Reg. 2018/1627) correct/ complete?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2019_4728
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Definition of encumbered assets

1. We have doubts whether assets that are held by the banks and obligatorily designated for the guaranteed deposit protection fund, according to the Act on Bank Guarantee Fund, Deposit Guarantee Scheme and Resolution, and deposited in an account kept separately for each bank, should be treated as encumbered assets? 2. We would like to clarify, whether assets held by banks in their current account in Central Bank (National Bank of Poland), or in affiliating bank in case of cooperative banks, or in cash as required minimum reserves, should be treated as encumbered assets.

  • 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: 2020_5475
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Annex V reference to ESRB Recommendation on closing real estate data gaps

Annex V to Regulation 680/2014, specifically Part 1.5(m) refers to ‘ESRB recommendation on closing real estate data gaps’ specifically to the 31 October 2016 version (ESRB/2016/14). Should this be interpreted as such that the definitions from ESRB/2016/14 are applicable for Finrep reporting, and the amended definitions from ESRB/2019/3 are not? Is this interpretation valid for both the currently applicable EBA framework 2.9 as well as for the announced (with final Annexes already available) EBA framework 3.0?

  • 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: 2020_5458
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

IFRS 9, validation rules v6012_m, v6013_m and v6014_m

In template F18.00 rows 211 to 231 for columns 120 and 140 and in template F19.00 rows 211 to 231 for columns 100 and 130 need to be opened. Validation rules v6012_m, v6013_m and v6014_m need to be deactivated as long as these positions are greyed out. These VRs may not be applicable for reporters under nGAAP that measure debt instruments at strict LOCOM and recognize accumulated impairment for performing exposures. Furthermore debt instruments measured at strict LOCOM under Austrian nGAAP are recognized as impaired assets in case there are negative credit-risk induced value adjustments.

  • 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: 2018_3930
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Validation rule v1251_m FINREP Taxonomy 2.8/2.9

Our question refers to EBA validationrule v1251_m which is, in our view, not always applicable. According to this rule F 05.01 [r010 c030] "Loans and advances from Credit institutions which are 'On demand [call] and short notice [current account]' must be equal to F 01.01 [r040 c010] 'Other demand deposits". The data point ‘On demand [call] and short notice [current account]’ in Template F 05.01 [r010 c030] includes ‘Loans and advances - On demand [call] and short notice [current account]’ from the accounting portfolio ‘Cash and cash balances at central banks’ as well as ‘Loans and advances - On demand (call and short notice (current account)’ from all other accounting portfolios ‘(..) other than Held for trading’. In our group Cash collaterals (paid) from OTC derivatives due to credit institutions are balanced as ‘Loans and advances. On demand (call and short notice (current account)’ in the accounting portfolio 'Financial assets at amortised cost' [F 01.01 r183 c010]. It is in our view not appropriate to report these collaterals as ‘Other demand deposits’ in F 01.01 [r040 c010 because they are no “Cash equivalents” according IAS 1.54(i) and because they are only payable when the contract is closed out. Therefore v1251_m is not a blocking validation rule and F 05.01 [r010 c030] can not (always) be equal to F 01.01. [r040 c010].

  • 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: 2020_5279
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

F 04.04.1, v5662_s.

ERROR : v5662_s: [F 04.04.1 (All rows, c050;060;070;080;090)] (F 04.04.1) <= 0 The validation rule is not correct. It shouldn’t include the row 150 ( of which : purchased credit-impaired financial assets) for which it is possible to have a positive value. It is possible to have a positive impairment for the purchase credit-impaired financial assets.

  • 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: 2018_3876
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

LtV calculations in FINREP

Should only ‘commercial immovable property collateral’ be included in the LTV calculations to be reported in Finrep templates F18.02 and F23.03? Additionally, should any collateral value allocation be applied in these same LTV calculations in case a ‘commercial immovable property collateral’ secures both an outstanding loan and at the same time an off-balance sheet item, or can the full commercial immovable property collateral value be allocated to the outstanding loan amount?

  • 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: 2020_5457
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Validation rules V_7329; V_7403 and V7409

Does validation rule V_7329; V_7403 and V7409 apply for columns that can (should) contain a negative amounts?

  • 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: 2020_5277
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Validation rules v5267_m up to v5279_m

This question is for validation rules v_5267_m up till v_5279_m.Validation rule v_5267_m requires the following condition is fulfilled:  sum({F 18.00.a, c010, (r010, r181)}) = sum({F 20.04, r080, c012, (sNNN)}). Is this validation rule 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: 2018_3852
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

FINREP Template 25.01 FX results and vintage buckets

In template F25.01 Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E): Inflows and outflows is requested. How do we report FX differences for the period and especially for the vintage buckets (columns 0050-0100)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2020_5456
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Template FinRep F01.03 Balance sheet Statement - Equity

In annex IV the line 030 "Unpaid capital which has been called up" of Template F01.03 has its reference IFRS in "black" as if this line has not to be remitted in IFRS Standard. In Annex III this line is also in black in column reference but the line is present in the Template (that i call drawn on the Template). It is the only cell drawn in black in templates full IFRS present in Annex III, and no comment explain what it means. Other lines with NGAAP BAD references are not present in the templates (for example lines 201 to 209 of the same Template F01.03 are not drawn). When we remit this Template on XBRL remittance gate ONEGATE of ACPR this cell is gray and is not required. But is it the choice of French NCA. Do the NCAs have choice to ask this line or not ? Have the establishments the choice ? Is it an error in Template IFRS, in fact this line has not to be present ?

  • 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: 2018_3805
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

COREP C17.01 - Consistency of the EBA Taxonomy control v5839_m

Does the Control v5839_m take into consideration the possibility to report a correlated incident?

  • 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: 2020_5434
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

EBA validation rule v5313_m and v5315_m don`t work in Tax 2.9

EBA validation rule v5313_m and v5315_m don`t work in Tax 2.9

  • 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: 2020_5274
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Validation rule (taxonomy 2.6) e4902_n about the risk weighted exposure for Equity in CR SA

Where shall equity exposures treated according to Articles 48(4), 471(2) and 495 (1) CRR be reported in COREP CR SA (C 07.00)?

  • 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: 2017_3414
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Treatment of deducted exposures in the calculation of memo items “Risk-weighted exposure amount under SEC-ERBA” and “Risk-weighted exposure amount under SEC-SA” ({C14.01 c447} and {C14.01 c448} respectively)

How to treat deducted exposures in the calculation of the mentioned memo items, to allow for a coherent and homogeneous comparison between the own funds required by the different methods?

  • 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: 2020_5422
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Treatment of derivatives not recognized on-balance under national GAAP

In case derivatives are not recognised on the balance sheet according to national GAAP based on BAD, how should they be treated for the purpose of FINREP and asset encumbrance 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: 2020_5263
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

FORBERANCE CLASSIFICATION

For forborne exposures under probation which, at the time of the initial concession, were performing, if a new measure is granted after 1 year and a half, during which the client has fulfilled points c) and d) of standard 176 when it is still within the probation period, and if the bank, on the basis of its own independent evaluation, does not reclassify the client (see Q&A EBA 2013_618 and 2014_736), is the period of 2 years for exiting the probation period counted again from scratch?Nel caso di una esposizione forbone under probation, che nel momento della prima concessione era performing, se una nuova misura viene concessa dopo 1 anno e mezzo durante il quale il cliente ha rispettato i punti c) e d) dello standard 176, quando è ancora in vigore il periodo probatorio, e se la banca in virtù della propria autonoma valutazione non riclassifica il cliente (vedi Q&A EBA 2013_618 e 2014_736) il conteggio dei 2 anni per l’uscita dal periodo probatorio, riparte da zero?

  • 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_1842
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Sign convention for “Credit risk adjustments during the current period” {C14.00 c225} and definition of "current period".

The sign convention that should be followed to report credit risk adjustments in column 225 of C14.00 is not clear. In the same way, the “current period” should be further specified.

  • 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: 2020_5421
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Sign Convention

Column 030 in C 07.00 (-) VALUE ADJUSTMENTS AND PROVISIONS ASSOCIATED WITH THE ORIGINAL EXPOSURE) has negative sign, while in C 09.01 columns 050to 070 has (+) sign convention. We would like to know that what is the rationale behind having different sign convention for same fact?

  • 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_1625
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021