Question ID
2025_7365
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
Article/Paragraph
11 / Section 2 to Annex I
Type of submitter
Credit institution
Subject matter
Table F12.01 – Movements in allowance and provisions for credit losses
Question

Considering the greyed out columns in row 350 and 550: How can the actual movement of impairment be reflected correctly?

Background on the question

For row 550 (Commitments and financial guarantees given (Stage 2): of which: non-performing exposures) and row 350 (Allowances for debt instruments with significant increase in credit risk since initial recognition but not credit-impaired (Stage 2) of which: non-performing exposures) several columns are greyed out. For row 550 even column 40 (Changes due to change in credit risk (net)) is blocked (which is not the case for row 350).

 

The only columns that are not blocked for row 550 are column 50 (Changes due to modifications without derecognition) and column 80 (Decreases in allowance account due to write-offs), which are in our opinion not enough to describe the detailed movement in this row.

 

We think that greying out some of the fields is not correct, because one cannot reflect the actual movement of impairment correctly and the template must be corrected accordingly.

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question