Submission #5

AFME

Question 1 (on template F 02.00) Do respondents agree with the proposed FINREP representation of “Contributions to resolution funds and deposit guarantee schemes” as part of “other operating expenses”? If not, which representation would you suggest? Please refer to document attached.

Question 2 (on templates F 13.2.1 and F 13.3.1) ‘Accumulated negative changes’ tries to capture, in a generic manner and independently from the type of collateral, the accumulated decrease in the value of a collateral item obtained, where the value of the collateral decreased since it was obtained by the institution (i.e. cases of increases in the collateral value are excluded). In this regard, 'accumulated negative changes' captures the net impact of changes in market prices, impairments and reversals of impairments, write-offs, depreciation and appreciation, change of accounting policies and similar on the carrying amount of an individual collateral item, where the difference between the value at initial recognition and carrying amount, as influenced by this factors, is negative. The comparison between value at initial recognition and the carrying amount at the reference date shall be done for each collateral item separately. In order to obtain the aggregate figure that is reported in the template, only the negative differences shall be aggregated, while cases of positive differences are to be neglected. Is this definition clear? Please refer to document attached.

Question 3 (on several templates, see F 18.00) The ESRB recommendation defines CRE as follows: ‘Commercial real estate’ (CRE) means any income-producing real estate, either existing or under development, and excludes (a) social housing; (b) property owned by end-users; (c) buy-to-let housing. If a property has a mixed CRE and RRE use, it should be considered as different properties (based for example on the surface areas dedicated to each use) whenever it is feasible to make such breakdown; otherwise, the property ca be classified according to its dominant use. ‘Commercial reals estate (CRE) loan’ means a loan aimed at acquiring a CRE property (or set of CRE properties) or secured by a CRE property (or set of CRE properties). ‘Income-producing real estate’ means all immovable properties with income generated by their rents or profits from their sale. Is this definition clear? To which extent is compatible with, for example, your internal classification? Which challenges with regard to the practical application of this definition do you envisage? Please refer to document attached.

Question 4 (on several templates, see F 18.00) The ESRB recommendation defines the current loan-to-value ratio as follows: ‘Current loan-to-value ratio’ (LTV-C) means the sum of all loans or loan tranches secured by the borrower on a property at the reporting date relative to the current value of the property; ‘Current value of the property’ means the value of the property as assessed by an independent external or internal appraiser; if such assessment is not available, the current value of the property can be estimated using a real estate value index sufficiently granular with respect to geographical location and type of property; if such real estate value index is also not available, a real estate price index sufficiently granular with respect to geographical location and type of property can be used after application of a suitably chosen mark-down to account for the depreciation of the property; Is this definition clear? Which challenges with regard to the practical application of this definition do you envisage? Please refer to document attached.

Question 5 (on F 40.01, F 40.02) The information included in the two group structure templates is currently collected on an annual basis. Without prejudice to notification obligations under national laws, a more frequent collection (quarterly) would improve the timely reflection and awareness of changes to institutions’ group structures. Which benefits and challenges with regard to the compilation and reporting of this information on a more frequent basis do you envisage? Please refer to document attached.

Question 6 (on F 44.04, F 48.00) Some of the items included in templates F 44.04 and F 48.00 are also collected for the purposes of benchmarking in accordance with EBA’s Guideline on the remuneration benchmarking exercise (EBA/GL/2014/08). The items requested in FINREP are of high-level nature and full alignment has been sought to keep the reporting burden limited. What is your view on the inclusion of this information in FINREP? Do you see any inconsistencies between this data and the data collected in accordance with the GL on remuneration benchmarking exercise that impact the reporting burden? Please refer to document attached.

Question 7 (on several templates, see F 23.01 – F 23.03) The following templates (templates F 23, F 24, F 26, F 47) request information on loans and advances subject to definition of non-performing and forborne exposures (with the exception of loans and advances classified as held for sale), in contrast to F 18 and F 19 that cover ‘exposures’ in a broader sense, e.g. also debt securities. The rationale behind applying these additional templates to loans and advances only is that the majority of exposures in credit institutions’ balance sheets that turned non-performing are loans and advances. To have risk based focus to monitor evolution of asset quality and to balance reporting burden the templates focus on loans and advances only. Are the definitions and instructions on the definition of the scope clear? Please refer to document attached.

Question 8 (on F 48.00) The information collected in this template is different in nature from the information collected in the remainder of FINREP, i.e. it is mostly of non-financial nature. It is valuable as contextual information to understand core elements of fixed costs of institutions. Similar information, where applicable potentially with regard to a different scope of consolidated entities, is collected, for example, by monetary authorities. Which benefits and challenges with regard to the compilation and reporting of this information do you envisage? Please refer to document attached.

Question 9 Are the scope of application of the revised reporting requirements as set out in the draft ITS above, the reporting templates as set out in Annexes 1 and 2 to this Consultation Paper (Annexes III and IV to the ITS) and the related instructions in Annex 3 to this Consultation Paper (Annex V to the ITS) sufficiently clear? In case of uncertainties with regard to scope of entities subject to the reporting obligation or the information that shall be reported, please provide clear references to the applicable provision respectively the relevant columns/rows of a given template as well as specific examples that highlight the need for further clarifications. Please refer to document attached.

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Name of organisation AFME