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IFRS 9 Transitional Arrangements - Business Combination

There is a business combination between banks which decided to apply the static and dynamic phase in the arrangements envisaged by Article 473a CRR. 1) How should the static phase-in arrangements envisaged by Article 473a CRR apply on the consolidated basis? 2) How should the dynamic phase-in arrangements envisaged by Article 473a CRR apply on the consolidated basis?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4391| Topic: Accounting and auditing| Date of submission: 25/11/2018

Interaction between Articles 473a and 127 of the CRR (risk weight factor for exposures in default under the standardised approach)

Do banks in order to calculate the thresholds of Article 127 of Regulation (EU) No 575/2013 (CRR) have to consider all IFRS 9 provisions (without applying any scaling factor) or the amount of IFRS 9 provisions reduced by applying the scaling factor as per Article 473a?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3931| Topic: Accounting and auditing| Date of submission: 24/05/2018

IFRS 9 Transitional arrangements – Calculation of the total exposure measure of the leverage ratio

According to Article 473a(7)(b) of CRR, is it correct to adjust the specific credit risk adjustments by applying a scaling factor for the only exposures subject to the standardised credit risk approach for the purpose of the calculation of the total exposure measure of the transitional leverage ratio?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio

ID: 2018_3995| Topic: Accounting and auditing| Date of submission: 13/06/2018

Article 473a(2) – Consideration of accounting provisions for FVOCI debt instruments

Should the ECL on debt instruments classified at fair value through OCI under IFRS9 be included within the calculation of the amount to be added back to CET1 as set in Article 473a.2 ( “static approach”)?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3932| Topic: Accounting and auditing| Date of submission: 24/05/2018

Recalculation of thresholds of Article 48 CRR due to IFRS 9 transitional arrangements (Art. 473a)

Do the thresholds of Article 48 of Regulation (EU) No 575/2013 (CRR) have to be recalculated in the context of Article 473a(7) as well, taking into account the amounts added back to CET1 due to the application of Article 473a?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3784| Topic: Accounting and auditing| Date of submission: 02/04/2018

Computing the amounts mentioned in Article 473a(2)(b) CRR, in case of the credit-impaired financial assets measured at amortised cost.

Should the amounts mentioned in Article 473a(2)(b) of Regulation (EU) No 575/2013 (CRR), as modified by Regulation (EU) No2017/2395 be: the total IFRS 9 Expected Credit Loss at transition date - point (i) and the amount of IAS 39 impairment losses at the day before transition date – point (ii), in case where there’s no modification regarding the reporting of the credit-impaired financial assets’ gross carrying amount (IFRS 9 vs IAS 39); the total adjusted IFRS 9 Expected Credit Loss at transition date - point (i) - see details below - and the amount of IAS 39 impairment losses at the day before transition date – point (ii) or the total IFRS 9 Expected Credit Loss at transition date - point (i) and the adjusted amount of IAS 39 impairment losses at the day before transition date – point (ii) – see details below, in case where the reporting of the credit-impaired financial assets’ gross carrying amount is modified (IFRS 9 vs IAS 39).

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3781| Topic: Accounting and auditing| Date of submission: 28/03/2018

Calculation of the sf factor as per Article 473a(7)(b) of Regulation (EU) No 575/2013 (CRR)

Please clarify whether "RAsa" which is used for the calculation of the “sf” factor, as per Article 473a(7)(b) of the CRR, should be gross or net of tax

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3783| Topic: Accounting and auditing| Date of submission: 30/03/2018

IFRS 9 Transitional arrangements - Definition of ‘t’

How should “t” which is used in the formulas in paragraph 1 of Article 473a CRR be calculated?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4113| Topic: Accounting and auditing| Date of submission: 13/07/2018

IFRS 9 Transitional arrangements – Reference date for the regulatory expected loss in Article 473a(5)(c)

Which date should apply to the regulatory expected loss for the application of Article 473a(5)(c)?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3953| Topic: Accounting and auditing| Date of submission: 01/06/2018

IFRS 9 Transitional arrangements - Distinction between defaulted and non-defaulted exposures for the calculation provided for in Article 473a(5)

Should an institution make the calculation in Article 473a(5)(a) of CRR separately for defaulted and non-defaulted exposures?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3952| Topic: Accounting and auditing| Date of submission: 01/06/2018

IFRS 9 Transitional arrangements - Calculation of the amount of CET add-back in accordance to Article 473a – paragraph 4

How should the amount referred to in Article 473a(4) be calculated: a) The difference between the Expected Credit Losses (ECL) at reporting date for loans that are not credit impaired and the ECL at implementation date for all the loans that are not credit impaired at the implementation date, or; b) The ECL at reporting date for loans that are not credit impaired minus the ECL at implementation date for those same loans?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3927| Topic: Accounting and auditing| Date of submission: 23/05/2018

IFRS 9 Transitional arrangements – Reporting of impact on Standardised exposure value of transitional credit risk adjustments

According to Article 473a(7)(b) of CRR, is it possible to report the impact on Standardised exposure value of transitional credit risk adjustments in COREP at an overall level?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3926| Topic: Accounting and auditing| Date of submission: 23/05/2018

IFRS 9 Transitional arrangements - Calculation of the amount available for CET1 add-back

When assets were measured at amortised cost in accordance with IAS 39 then classified as FVTPL under IFRS 9, should they be included in the calculation of the ‘day 1’ static amount to be added back to CET1 as set in Article 473a(2)(b)?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3925| Topic: Accounting and auditing| Date of submission: 23/05/2018

IFRS 9 Transitional arrangements – Reversal of the decision to apply the transitional arrangement

What should be understood as reversal of the initial decision and, as such, be subject to the prior permission of the competent authority? Which are the possible scenarios?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3924| Topic: Accounting and auditing| Date of submission: 23/05/2018

IFRS 9 Transitional arrangements - Calculation of the amount available for CET1 add-back

Should off-balance sheet exposures not be included in the calculation of the amount of CET1 add-back?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3923| Topic: Accounting and auditing| Date of submission: 23/05/2018

IFRS 9 transitional provisions – Calculation of the increased amount of risk-weighted assets (RWA) in the standardised approach

Should the RWA correction (also with regard to the presentation in the Corep template 5.1) according the details in the background be calculated as follows: total amount of provisions multiplied by the scaling factor and then finally weighted by the risk weightings for each of the exposures for which these provisions were calculated?   *** Muß nun die RWA-Korrektur (auch in Hinblick auf die Darstellung im Corep Template 5.1.) wie folgt berechnet werden: Gesamtbetrag der Risikovorsorgen multipliziert um den Faktor und schlussendlich versehen mit den jeweiligen finalen Risikogewichten jener Exposures, für die diese Risikovorsorgen gebildet wurden?    

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_3664| Topic: Accounting and auditing| Date of submission: 12/01/2018

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