Single Rulebook Q&A

Question ID: 2016_2568
Legal act : Regulation (EU) No 575/2013 (CRR) as amended
Topic : Supervisory reporting
Article: 99
Article/Paragraph : Annex 1 - Table 2A2 - row 030
COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions
Type of submitter: Other
Subject matter : Reporting of funding, obtained to supply credit to the real economy, and validation rule v4137_m

Should in table P 02.02, row 030, only the obligations be reported, which arise through the issuance of debt securities or is the reporting of loans from multilateral financial institutions and public financial institutions expected as well?

Background on the question:

In table P 02.02 (Public sector sources of funding), row 030, National and supra-national term (greater than one year) credit supply incentive scheme to the real economy - amount of funding outstanding under such programmes should be reported. Definitional reference says: "The form of support referred here is intended to capture wholesale secured or unsecured term debt issuance support to credit institutions to issue for the sole purpose of credit intermediation to the real economy via pricing or quantum incentives from a national and/or supra-national authority." According to the validation rule v4137_m: {P 02.02, r030} <= {P 01.02, r180} only funding through debt securities issued is expected to be reported in this item. In our view the loans granted to credit institutions by public or multilateral financial institutions with the purpose of supplying credit to the real economy should also be covered in this item. Loans from such institutions ccan be an important source of funding for the banks. An example would be promotional-development financing programmes to the real economy, which are carried out by a public financial institution in the form of loans to banks as intermediates. If the validation rule v4137_m is to be followed, such funding would not be reported in table P 02.02, row 030. In our view funding from multilateral financial institutions in the form of loans should be covered as well.

Date of submission: 14/01/2016
Published as Final Q&A: 15/06/2018
EBA answer:

According to the instructions to the funding plan templates, row 030 of P 02.02 captures support to wholesale secured or unsecured term debt issuances. Reported data shows how much of a bank’s issued debt is supported by pricing or quantum incentives (e.g. through “public sector guaranteed”; with initial maturity or first call date is greater than one year).

The idea of table is not that any direct funding from the public sector (e.g. state development banks) to a bank shall be reported here. I.e. public sector funding schemes as part of which e.g. a state bank provides loans to private banks, which in turn provide loans to households or non- financial corporations, are not captured by this table. For future versions of the funding plan template it will be considered if a separate row for such public sector sources of funding shall be implemented, as they are not covered by the current version of the funding plan templates.

Status: Final Q&A
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