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List of Q&A's

Number of Collateral obtained by taking possession, F 25.02.b - Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E)

How to calculate the number of collaterals obtained in case of securities? Should it be the number of issues or the number of securities within the issue?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_5248
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

EBA/ITS/2020/05 - COREP-Template 35.03

We kindly ask for clarification which exposures shall be reported in template C 35.03. Do we interpret correctly that only those exposures shall be reported which fulfill the following conditions (of Art. 47c (6)): a) only one forbearance measure was granted after the classification as non-performing of the account b) this first forbearance measure was granted during the 2nd year of classification as non-performing if related to the unsecured part of the exposure/account c) this first forbearance measure was granted during the 3 - 6 year of classification as non-performing if related to the secured part of the exposure/account d) the (first) forbearance measure was granted during the last 12 months

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_5509
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

FinRep Table 26: Loans and advances to which forbearance measures were granted in addition to already existing forbearance measures

It is unclear if the following exposures have to be reported in row 120 of template F 26.00: - Example A : an exposure was classified as non-performing with forbearance measures and fulfilled all required exit criteria mentioned in paragraph 231. During the 2 year probation period mentioned in paragraph 256 the exposure is granted an additional forbearance measure. At the reference date the exposure is classified as non-performing because the new forberance measure has been extended to a performing forborne exposure under probation that has been reclassified out of non-performing category (according to paragraph 260). - Example B : a performing exposure is granted a forbearance measure. During the 2 year probation period the exposure is granted an additional forbearance measure. According to Q&A 2014_736 the exposure shall not be automatically reclassified into the "non-performing forborne" category and then at the reference date the exposure is classified as performing. - Example C: a performing exposure is granted a forbearance measure. During the 2 year probation period the exposure is granted an additional forbearance measure. According to Q&A 2014_736 the exposure shall not be automatically reclassified into the "non-performing forborne" category. Nevertheless, if the bank considers that there exist some conditions of "unlikeliness to pay", the exposure A shall be reclassified into the "non-performing forborne" category. Then at the reference date the exposure is classified as non-performing.

  • 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_5239
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Failed XBRL rule v5713_s: [F 46.00 (r100;110;140, c010;020)] {F 46.00} <= 0

Can we keep our reporting for 2019 as it is and will row 130, column 20 be opened for this purpose? We think that this is correct presentation.

  • 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_5301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Reporting of margins in C34.02 and in C34.08 under OEM and simplified SA-CCR methods

According to dpm3.0 in the current version, collateral that was taken into account in the calculation of the CCR exposure, must be shown in form C34.02 in columns 0060-0090. The columns 0060-0090 are grayed out for OEM. These margins are to be shown in more detail in form C34.08. The question: within the scope of the calculations according to Art. 282 (OEM) and Art. 281 (simplified SA-CCR), the margins are covered in the formula of replacement costs (RC = TH + MTA). The margins therefore generally have no direct impact on the calculated assessment basis. That is why the margins are not to be reported: - in columns 0060-0090 of form 34.02 for simpl. SA-CCR analogous to OEM and - in form 34.08 for both methods (simplified SA-CCR and OEM). Is this assumption correct?

  • 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_5508
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Validation rule eba_v6295_m

When a just established bank has nothing to report yet in the Corep and therefore reports a nil report, two validation rules fails: validation rules eba_e4887_e and eba_e4888_e. This concerns two cells r850 and r860 on C04.00 that should be filled. After filling in a zero in these cells the two validation rules do not appear anymore, but a new validation rule is failing now: eba_v6295_m ([C 04.00 (r860)] {c010} &gt; 0 and {c010} != empty). Apparently a zero is not permitted. Is it possible to change the validation rule to greater to or equal to 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: 2020_5120
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

FINREP Loan commitments, financial guarantees and other commitments given

What should be reported in columns 0100 and 0110 for “Other commitments measured under IAS 37 and financial guarantees measured under IFRS 4” for loan commitments given?

  • 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_5495
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

C76 – Updated LCR Calculation tool

The excel formulae in the updated LCR Calculation tool does not appear to be correct

  • 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_5290
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Clarification of F 24.01, row 0310

What is expected to be reported in F 24.01, row 0310 ("Outflow of non-performing exposures that became non-performing during the period") as specified in paragraph 334 of Annex V, Part 2? Could you provide clarification on how to fill this row consistently with the instructions provided in paragraph 239iii of Annex V, Part 2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2019_5066
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

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) &lt;= 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&amp;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