List of Q&As

COREP templates to be submitted on a semi-annual basis.

The draft ITS (Articles 5(b), 6(b), 8(1)(b), 8(2)(b) and 12) and the CRR mention that OPR details, CR SEC details, Group Solvency and Losses on Immovable Properties templates are to be submitted on a semi annual basis. Can you confirm that the first reporting date for these templates will be 30 June 2014?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_244| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 13/09/2013

FINREP F13.1 row 010 Loans and advances col. 050 Financial guarantees received

What is the information that should be included in this box? Is it the whole amount of financial guarantees received, or is it the value of those financial guarantees received that are related to loans and advances collateralized by immovable properties or any other in rem guarantee? In other words, if a loan has only financial guarantees, and none of those included in columns 010 - 040, shall that financial guarantee be included in row 010 & column 050?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_236| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 11/09/2013

FINREP - Contents of templates 7 and 5 - Row "On demand [call] and short notice [current account]"

We wonder about the reporting of overnight accounts and advances and on the scope of templates 5 and 7: - overnight accounts and advances with counterparties "central banks and credit institutions" are not reported on a "loans and advances" row in table 1.1 but on the rows 030 et 040 ; nevertheless, do they have to be reported in tables 5 and 7 which concern "loans and advances" ? If yes, do they have to be reported on the row "On demand [call] and short notice [current account]"? - does overnight accounts and advances with other counterparties have to be reported on the row "On demand [call] and short notice [current account]" in tables 5 and 7 ?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_235| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 11/09/2013

Annex XV Validation formulae, "≡" vs "="

We would like to know what the differences are, for the validation formulae purpose, between the symbols "≡" and "=". E.g: Validation {F 20.04 , r140 , c030}≡{F 20.07 , r190 , c020} (without ID). Does this validation mean that the value of both "boxes" o "line items" is the same or, on the contrary, that the "concept" they both refer to is the same? We though it was the first option until we bumped into this question. If it were the second alternative, should it appear in the majority of validation links?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_231| Topic: Supervisory reporting - Other| Date of submission: 10/09/2013

FINREP F45.2

Row 010 "Property, plan and equipment" has been eliminated. Notwithstanding, currently the first row (Investment property) is row 020, not row 010. Hence, should the row 040 "Other assets" include the information previously contained in row 010?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_219| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 09/09/2013

Annex III F20.4 row 210 Of which: Commercial immovable property

What is the information requested in this row? Does it consist of loans collateralized by commercial immovable property, similarly to row 230? Or is it made up of loans granted to acquire commercial immovable property?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_216| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 09/09/2013

Financial guarantees received and other commitments received (F 09.02)

1) Could you confirm that the item "Financial guarantees received" (see F 09.02, r080 – r140, c010) includes only financial guarantees received as collateral for the institution's liabilities and for institution's financial guarantees given or other commitments given (i.e. it does not include financial guarantees received as collateral for claims/financial assets, given the fact that they are considered as part of information in template F 13.01 Breakdown of loans and advances by collateral and guarantees)? 2) Consequentially we would like to clarify the treatment of other collateral received (either from the customer or from third party) for financial guarantees given and other commitments given (from template F 09.01). Should they be also included in item "Other Commitments received" of template F 09.02 (r150 – r210, c020)?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_214| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 05/09/2013

Specifying default fund contribution or risk weights in C07.00 and connection to C02.00.

First, according to column 020, default fund contributions is included in column 010 (original exposure) since it is a "of which". To get row 090 - 210 to sum up to the total exposure at row 010, the default fund contribution must then also be specified on row 090-210. Since the default fund contribution not is calculated with those fixed risk weights, on which row should the amount then be inserted? Secondly, should the amount in C07.00, c220, r010 be splitted on C02.00, row 460 and 050?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_209| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 03/09/2013

FINREP: F07.00 reporting of past due assets

How to split past due not impaired financial assets according to the number of days past due? According to the Instructions in Part 2, paragraph 48: “Assets qualify as past due when a counterparty has failed to make a payment when contractually due”. Q1: Will the whole asset/loan be qualified as past due or only its part, for which the counterparty failed to make a payment? According to the Instructions in Part 2, paragraph 48 : “The amounts of such assets shall be reported and broken down according to the number of days past due”. Q2: Should the individual financial asset/loan be split into parts according to the “age” of individual instalments or should the financial asset/loan be reported in the col. for the “oldest” past due instalment? In this case “to split” will be relevant to financial assets portfolio (= individual asset will be kept as a whole, but portfolio will be split) .

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_194| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 29/08/2013

Leverage Ratio: C45.00 (LRCalc) r010: SFTs exposure according to CRR 220

The exposure for repurchase transactions, securities or commodities lending or borrowing transactions, long settlement transactions and margin lending transactions should be calculated in accordance with Article 220 (1) to (3). Should the volatility adjustments be taken into account for the determination of the leverage ratio exposure value of exposures subject to Article 220?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_188| Topic: Supervisory reporting - Leverage ratio| Date of submission: 28/08/2013

FINREP: Counterparty breakdown - hospitals, schools, social secretaries

As what counterparty shall hospitals, schools and social secretaries be reported? Are there any thresholds (e.g. turnover) which when exceeded then the entity shall be reported as different counterparty (e.g. in current FINREP hospitals are treated households, when turnover exceed the limit then the hospital is reported as corporate)?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_184| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 26/08/2013

NSFR: Calculation of liablities and receivables from derivatives if there is no netting agreement

NSFR: How should the amount of liablities and receivables from derivatives be calculated if there is no netting agreement with the counterparty?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_183| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 26/08/2013

FINREP: F1.1. row 040 "other demand deposits"

On the basis of the validation rules of template F1.1, row 040 is part of the sum of row 010 'cash and cash balances at central banks'. So one can assume that row 040 'other demand deposits' are deposits with central banks. However, the guidance in annex V part 2.3 (1.1 assets - § 3) stipulates that 'other demand deposits' includes balances receivable on demand with credit institutions. This seems contradictory to us. Please can you confirm whether row 040 of template F1.1, comprises 'other demand deposits' with central banks or with credit institutions.

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_180| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 23/08/2013

FINREP: Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net

During the last update on the ITS Annex III in July 2013 the FINREP P&L template was modified by removing the line item for "Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net" (table 2 row 320 ITSoR March 2013) without any explanation. But in comparison with the published DPM in July 2013 which still contains the line item there is an inconsistency. In our opinion the line item is required to reach a consistent and meaningful P&L Statement, so that we assume that removing the line item is a mistake in the templates. If it is not an error it is necessary to give guidance on the disclosure of gains or losses on derecognition of investments in subsidiaries, joint ventures and associates.

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_178| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 22/08/2013

COREP C25.00 (CVA): rows 030 and 040 for column 110 shouldn't be reported

in CVA report, the column 110 is requested for all methods but when we check the definition of this column "number of counterparties where the credit spread was determined using a proxy instead of directly observed market data". This definition suits more for CVA advanced method but no for standard method nor for based OEM, our question is the proxy used to determine credit spread is it really requested for standard method or OEM?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_171| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 19/08/2013

FINREP validation rules - references to missing rows

In the Validation Formulae (Appendix XV), there are many rows referred to that do not exist in the template (Appendix III). For example, in table 1.1 it is referred to rows 091, 092, 093, 094, 095, 171, 172, 173, 174, 175, 176, 177, 178, 231, 232, 233, 234, 235, 236 and 237, which do not exist in the template. There are many other similar examples. How should we interpret/handle these validation rules?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_165| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 16/08/2013

FINREP Template F 06.00 - reporting by country

Template 6 - Breakdown of loans and advances to non-financial corporations by NACE codes and by residence of the counterparty. Should this table be delivered per country?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_161| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 14/08/2013

FINREP: Calculation of accumulated changes in fair values- first application

Is it possible to apply a starting date for calculation of accumulated changes in fair values?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_158| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 14/08/2013

FINREP - Company only IFRS reporting

Please confirm the reporting requirements for a broker dealer reporting stand-alone company accounts under IFRS. Current reading of the guidance suggests that such an entity would be out of scope.

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_153| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 12/08/2013

Validation Rules - Mistakes in the Annex XV

- In the validation rules file, a confusion is made between rows and columns in excel columns 'H' and 'I'. - The validation rule for row item 330 of the FINREP template F 01.01 is missing

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2013_152| Topic: Supervisory reporting - Other| Date of submission: 12/08/2013