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Eligibility of subordinated loans for classification as Tier 2 instruments when the rules governing their issue contemplate an obligation of the issuer to repurchase a percentage of them (eligibility limited to the amount of subordinated loans not subject to such repurchase obligation).
Pursuant to the combined application of articles 63 letter k) and 66 letter a) it is correct that a clause – also included in the rules governing the issue of subordinated loans – according to which an issuer is obliged to repurchase a specified amount of subordinated loans does not prevent from classifying such financial instruments as Tier 2 instruments if, in compliance with article 66 letter a), the percentage of subordinated loans that shall be repurchased by the issuer is deducted from Tier 2 items? In other words, a subordinated loans can be classified as Tier 2 instruments if the provisions governing their issue contemplate the undertaking of the issuer to repurchase a specified percentage of the issued subordinated loans provided that - in compliance with article 66 letter a) of CRR - such percentage is deducted from Tier 2 items? The undertaking of the issuer to repurchase part of subordinated loans deriving from the rules governing the issue of such subordinated loans can be considered as a repurchase “contractual obligation” and as a consequence may it fall within one of the cases contemplated under the provisions of article 66 letter a) of CRR?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2014_1226 |
Topic: Own funds |
Date of submission: 21/05/2014 |
Date of publication: 29/08/2014
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Validation Rule
Original question: Stimmt die EBA den folgenden validation rules für Spalte 070 zu: F07.00 (c070; r010) = F04.03 (c020; r010) F07.00 (c070; r020) = F04.03 (c020; r020) F07.00 (c070; r030) = F04.03 (c020; r030) F07.00 (c070; r040) = F04.03 (c020; r040) F07.00 (c070; r050) = F04.03 (c020; r050) F07.00 (c070; r060) = F04.03 (c020; r060) + F04.04 ((c020./.c030./.c040); r010) F07.00 (c070; r070) = F04.03 (c020; r070) + F04.04 ((c020./.c030./.c040); r020) usw. bis F07.00 (c070; r180) = F04.03 (c020; r180) + F04.04 ((c020./.c030./.c040); r130) Translated question: Does the EBA agree with the following validation rules for column 070: F07.00 (c070; r010) = F04.03 (c020; r010) F07.00 (c070; r020) = F04.03 (c020; r020) F07.00 (c070; r030) = F04.03 (c020; r030) F07.00 (c070; r040) = F04.03 (c020; r040) F07.00 (c070; r050) = F04.03 (c020; r050) F07.00 (c070; r060) = F04.03 (c020; r060) + F04.04 ((c020./.c030./.c040); r010) F07.00 (c070; r070) = F04.03 (c020; r070) + F04.04 ((c020./.c030./.c040); r020) etc. to F07.00 (c070; r180) = F04.03 (c020; r180) + F04.04 ((c020./.c030./.c040); r130)
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 (repealed)
ID: 2013_602 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 02/12/2013 |
Date of publication: 29/08/2014
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Own Funds - Subordinated loans as Tier 2 instruments
Our interpretation of Article 63 (g) of the Capital Requirements Regulation (Regulation 575/2013 is that subordinated loans which are perpetual (i.e. do not have a maturity date) would also qualify as Tier 2 instruments under article 63 (g) of the CRR, given that the original maturity would exceed five years (i.e. it would be for an indefinite period). Do you agree with our interpretation? Or is it only subordinated loans with a fixed redemption date (and whose original maturity is of at least five years) which should be recognised as Tier 2 instruments?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2014_1220 |
Topic: Own funds |
Date of submission: 20/05/2014 |
Date of publication: 29/08/2014
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Bestimmung der Forderungsklasse von Zentralbanken mit Gesellschaftsform Aktiengesellschaft (EN: Determination of the exposure class for central banks that take the form of a public limited company)
In welche KSA- und IRBA- Forderungsklasse sind die Aktien von (EU- Zentralbanken z.B. Griechenland) einzustufen? EN Translation: In which CRSA and IRBA exposure class are the shares of EU central banks (e.g. Greece) to be classified?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_586 |
Topic: Credit risk |
Date of submission: 29/11/2013 |
Date of publication: 29/08/2014
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Validations FINREP
Regarding FINREP validations: 1) v779_m / F 01.03: {r090} = {r100} + {r110} + {r120} + {r130} + {r140} + {r150} + {r160} + {r170} + {r180}. Why are {r122} and {r124} not also part of the formula? 2) cell (r90, c90) refers "Conversion of debt to equity", which is disabled for data entry. What is the reason?
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 (repealed)
ID: 2014_890 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 03/03/2014 |
Date of publication: 22/08/2014
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FINREP Template F20.4 (r210,r230)
In template 20.4 row 210 loans to non-financial corporations shall be broken down to “of which: Commercial immovable propertys”. In row 230 loans to household shall be broken down to “of which: loans collateralized by residential”. Are gross carrying amounts of loans formally collateralised by residential or commercial immovable property respectively required in rows 210 and 230? Or shall row 210 include gross carrying amounts of loans that are used to finance commercial immovable properties?
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 (repealed)
ID: 2014_864 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 20/02/2014 |
Date of publication: 22/08/2014
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Definition of assets with an undefined maturity date
May CIU shares which do not meet the requirements of article 416, paragraph 6 of the CRR, but that the institution may call and which are contractually repayable at any time within the 30-day time horizon, be considered as assets with an undefined contractual end and taken into account as inflows up to 20% their total amount?
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 (repealed)
ID: 2014_835 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 11/02/2014 |
Date of publication: 22/08/2014
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Audit of the FINREP figures
1) As regards FINREP reports, audited figures shall mean: - audited FINREP reports (i.e. the external auditor expressing an audit opinion on the FINREP reports as a whole) OR - building the FINREP reports based on final, audited figures existent in the accounting (i.e. based on the information from the annual published consolidated financial statements)? 2) What is the frequency of the auditing obligation in the case of FINREP information?
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 (repealed)
ID: 2014_834 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 11/02/2014 |
Date of publication: 22/08/2014
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Leverage Ratio, form 46.00
In the taxonomy, it seems that we have an open fact set on the cell Line 160 column 02. Although this cell is not mentioned in the ITS (only cells 160;1 and 160;3 seems to appear in the ITS). => May you confirm if the EBA expects or not to receive a fact for cell 160;2? => Will the ITS or the Taxonomy be updated accordingly?
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 (repealed)
ID: 2014_827 |
Topic: Supervisory reporting - Leverage ratio |
Date of submission: 10/02/2014 |
Date of publication: 22/08/2014
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Validations
Can the EBA review the attached file which includes specific validations which we believe may be illogical or contain errors. Where appropriate can the EBA amend both Annex XV and the taxonomy. Please note that this is not a repeat of question 2013_524. The attached file contains a further set of validation queries.
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 (repealed)
ID: 2014_815 |
Topic: Supervisory reporting - Leverage ratio |
Date of submission: 06/02/2014 |
Date of publication: 22/08/2014
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IIlogical validation in Annex XV
IIlogical validations in Annex XV
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 (repealed)
ID: 2014_809 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 04/02/2014 |
Date of publication: 22/08/2014
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Wrong member in the taxonomy categorization for ‘Type of risk’ dimension in column 040 of template F 13.01
In Report F 13.01 – Breakdown of loans and advances by collateral and guarantees, column 040 (Other collateralized loans – Rest) is interpreted, in the template, as being ‘Collateral other than real estate and other than Cash [Debt instruments issued]’. In this column, for dimension Main category of collateral or guarantees received, all members are being categorized as ‘Other than Real Estate’ while they should be categorized as ‘Other than Real estate, Deposits, Debt securities issued’ thus including other Deposits and Debt securities issued for collaterals other than real estate and being consistent with it’s Hierarchy for collateral received (MC22).
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 (repealed)
ID: 2014_789 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 29/01/2014 |
Date of publication: 22/08/2014
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Article 416 - Reporting on liquid assets
According to the answer of Question 2013_222, assets issued by credit institution with meeting any of the criteria from Article 416(2)(a)(iii) could be reported as liquid assets. However, where should it be reported?
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 (repealed)
ID: 2014_739 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 16/01/2014 |
Date of publication: 22/08/2014
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Classification of forborne exposure to non-performing
Para 179 states the if a performing forborne contract under probation is extended additional forbearance measures or becomes more than 30 days past-due, it shall be classified as non-performing. This is paragraph refers to those forborne exposure which have been reclassified out of the non-performing category and shall be reported separately under the performing forborne, or those is refer to all performing forborne exposures?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
ID: 2014_736 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 15/01/2014 |
Date of publication: 22/08/2014
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ITS on supervisory reporting under the CRR COREP CR GB template
What exposure value have to be taken into consideration to verify threshold of 10% of total exposures in all exposures classes according to Article 5 (a) (4)? Should the total exposures be taken as reported in row 010 column 010 of template 7 of Annex I as original exposure pre conversion factors? Which institutions should report information on the geographical distribution of exposures by country on template CR GB 1, CR GB 2? Should only those institutions report CR GB 1, CR GB 2 templates whose ‘non-domestic’ exposures are equal or higher than 10% of total exposures?
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 (repealed)
ID: 2014_702 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 03/01/2014 |
Date of publication: 22/08/2014
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Validation Rules
There are several validations that do not appear to be appropriate. 1. v1231_m and v1318_m These validations require the prior period closing balance to equal the current period opening balance. However, given there is a separate column for profit/loss attributable to the parent on table 46 (column 100), the opening balance will not equal the closing balance. 2. v2668_s This validation requires Table 46 rows 010-040,110,190,210, columns 90 and 110 to be
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 (repealed)
ID: 2013_663 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 16/12/2013 |
Date of publication: 22/08/2014
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Recognition of Cashflows for NSFR reporting
In case of partial payments on assets/liabilities, should each partial payment be reflected in the corresponding time bucket, or in total on the contractual maturity? Does this apply only to capital cashflows or also to interest rate cash flows?
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 (repealed)
ID: 2013_656 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 16/12/2013 |
Date of publication: 22/08/2014
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Capital eligibility in relation to intragroup guarantees - interpretation of "seniority"
How should we interpret "seniority" as used in Article 28(1)(l) of Regulation (EU) No 575/2013 (CRR) (and likewise in Articles 56(e) and 63(e))?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2014_903 |
Topic: Own funds |
Date of submission: 05/03/2014 |
Date of publication: 22/08/2014
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Definition of Accumulated Writte-Offs to be reported in column 110 of Table 7
The ITS 2.49 defines accumulated write-offs as follows: The column “Accumulated write-offs” includes the cumulative amount of principal and past due interest of any debt instrument that the institution is no longer recognizing because they are considered uncollectible, independently of the portfolio in which they were included. These amounts shall be reported until the total extinguishment of all the institution’s rights (by expiry of the statute-of–limitations period, forgiveness or other causes) or until recovery. Does this amount refer to the write-offs from the initiation of the exposure, or only cumulatively, as it relates to the current reporting period (please specify if year or quarter)?
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 (repealed)
ID: 2013_643 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 12/12/2013 |
Date of publication: 22/08/2014
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Underwriting Commitments
Can underwriting commitments as described under Article 345 of the CRR be included in the Exposure measure of the Leverage ratio?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2014_839 |
Topic: Leverage ratio |
Date of submission: 11/02/2014 |
Date of publication: 22/08/2014
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