Response to consultation on ITS on Supervisory Reporting amendments with regards to COREP securitisation

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Question 2: Are the instructions and templates clear to the respondents?

Under Article 254(3) of the new CRR, banks will be allowed to use the SEC-ERBA instead of the SEC-SA for all of their rated securitisation positions. We assume that banks which make use of this option will only have to complete columns 0590 and 0760 of the required breakdown in columns 0580-0610 and 0750-0780 in template 13.1. Otherwise, they would have to calculate amounts using the SEC-SA as well, which would be an unreasonable additional burden, in our view.

Name of organisation

German Banking Industry Committee