EBA E-mail alert March 14, 2025

Could you please clarify how fully matured loans and deposits should be presented in templates F05.01 and F08.01?

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of CRR? 

Where counterparty sector breakdown applies, it is required more guidance on how to classify a CCP which have the banking license. For instance, in template F10, where should we report derivatives positions we have with a QCCP which at the same time is (i) a clearing house and (ii) a credit institution (included in the list of ECB’s supervised banks)?

We face the ambiguity in classification in further reporting frameworks both supranational (e.g. G-SIB data collection exercise, FSB)  and local (i.e. Circolare 262 Banca d’Italia on Financial Statements).

On report F09.02, banks are asked to report guarantees received as collateral, partly in column 0010 and partly in column 0020. Where some questions have been answered in earlier Q&As, some questions remain:

Based on Q&A 2013_214, guarantees received on off-balance sheet exposures should be reported as "Other Commitments Received". These are reported in F09.02 Col0020.
Based on Q&A 2023_6773, in F09.02 Col0010, guarantees are considered by ignoring other collaterals.

Should other collaterals be considered in calculating the amount reported in column 0020?

Along the same lines, how should calculations work for both columns 0010 and 0020 if multiple guarantees are received? Within the same group of exposures and its/their contractually linked collaterals/guarantees, should they all be calculated separately and independently, ignoring the existence of other guarantees within the same group similar to the way other collaterals in the same group are ignored?

The ITS states that "For other commitments received, the nominal amount shall be the total amount committed by the other party in the transaction." is to be reported in column 0020.  Does this also apply in the case whereby a guarantee is received to secure an (off-balance) exposures? In other words, should it be capped at the Off-Balance Exposure Amount or not?

With reference to the Q&A 6852, we kindly request clarification on the appropriate logic to utilize when adding the amounts of the unused portion of the GPP for the rows in Template M 01.00, specifically rows 0250 to 0290.

We would greatly appreciate if you could provide guidance on the correct allocation of the unused amount for rows 0260, 0270, 0280, 0285, and 0290. Given that the GPP has a duration of one year, it is our understanding that the unused amount should be accounted for solely in rows 0250 and 0285, as per convention.

Can you provide more guidance on the amounts to be reported for “Change in fair value for the period” and “Accumulated change in fair value before taxes” in particular for derivatives falling under netting agreement and recognized with accounting offsetting?