EBA E-mail alert March 21, 2025

Should an open-end investment fund be considered an obligor under Art. 178 (1) CRR, irrespective of whether it has legal personality under a Member States’ regulations on investment funds?

How should exposures subject to a risk weight of 70% according to Art. 126 (2) CRR3 be reported in the ITS on supervisory reporting v4.0? Should these exposures be included in the row r0280 “other risk weights” of the template C 07.00?

Where in the sheet C01.00 of the COREP, can we deduct CIUs under fallback approach (subject to 1250% RWA) from CET1 (as permitted by article 36.1.k.vi) since no dedicated caption is currently foreseen?

we have a suspicion of schizophrenic modeling on the new C1000 report.

 Indeed on this report when we look at the annotated templates it seems that all cells from column 0090 are sharing the same XBRL address as their corresponding cell for the same row from column 0100.

Which means that from a technical point of view we will only be able to submit one “amount” per pair of cells C0090/C0100 for a dedicated row.

For instance the Annotated templates stats that :

{C_10.00, r0060, c 0090, s0000}=={C_10.00, r0060, c 0100, s0000} 
VariableID 3295841 
VariableVID = 3295841 

In the same time when we look at the ITS :

• We understand that may be possible that the transitional provisions do not apply  and so that or instance amount reported in cell 0020 _ 0090 can be equal to the amount in cell  0020 _ 0100 where the amount expected  for both cell is zero. 
• But we do expect from our understanding of the ITS that the transitional provision may apply and that the impact should be reported in various rows. In this case we will need to report different amounts on a specific row for those two columns, which seems unfeasible with the current setting.

Do you agree with our understanding?

Could you kindly clarify if, in the context of map C02 , the comparison should be made with line 0036 instead of line 0010, considering that the output floor is calculated at the consolidated level and not at the contract level?