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Liquidity: First submission date for Stable Funding template
EBA-ITS-2013-02 Article 18 (7) states: "for the period from 31 March 2014 to 31 December 2014 as a deviation from point (a) of Article 3 (1) the reporting remittance date relating to monthly reporting shall be the 30th calendar day after the reporting reference date". This would mean that the first submission of the LCR template should be by 30 April 2014, but we question whether this should also apply for the first submission of the SFR template? As things stand, it would appear that the first submission of the SFR template should be in line with Article 18 (6).
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_106 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 31/07/2013 |
Date of publication: 14/02/2014
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COREP: Validation rules on draft ITS for C19.00 (MKR SA SEC)
In this return (C 19.00 MKR SA SEC) we are asked to complete the average risk weight (%) for securitisations going through the supervisory formula approach and the internal assessment approach, in columns 260, 290, 490 and 520. The validation rules in Annex XV specify that these % figures are simply added together, as for any other columns on the return. This produces a mathematically nonsensical result. For example, for the total row (row 010) we should add together the average % amounts from each securitisation category, to reach a total average %. The total is thus the sum of the average %s of each row, a figure that owes more to how many rows are being completed than to any particular value. % Would it not be more mathematically sensible to take the average % of the total? In other words, to replace the existing {r010,c260} = {r030,c260} + {r060,c260} + {r090,c260} with {r010,c260} = {{r030,c260} * {r030,c250}} + {{r060,c260} * {r060,c250}} + {{r090,c260} * {r090,c250}} ? Or if this is not suitable, to not calculate the value at all?
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_102 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 29/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 41.2 Use of the fair value - Crossing col 030 "Hybrid contracts" / Row 020 "equity instruments"
FINREP Template 41.2 Use of the fair value - Crossing col 030 "Hybrid contracts" / Row 020 "equity instruments" : this crossing is forbidden ; even if few cases are expected, how do we have to report possible occurrences ?
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_97 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount"
FINREP - Template 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount" : for entities with a different accounting treatment under IFRS Group scope and under CRR Group scope, the amount related to which scope is expected ?
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_96 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 40.1 Group structure "entity-by-entity" - Col 080 "Profit or (-) loss of investee"
FINREP - Template 40.1 Group structure "entity-by-entity" - Col 080 "Profit or (-) loss of investee" : which result is expected in column 080 : "profit or loss for the period" or "total comprehensive income for the period" ?
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_95 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 40.2 Group structure "instrument-by-instrument"
FINREP - Contents of template 40.2 Group structure "instrument-by-instrument" : we don't understand the scope of templates 40.2 : do we have to report all securities in our portfolio issued by an entity included in our accounting scope ? The amounts expected in columns 030 to 050 (holding company) are related to the security or to the holding company ? We need further explanations"
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_93 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope
FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope : we understand that the scope to be considered for the templates 40.1 and 40.2 is the Accounting Group (including insurance companies for example) and not the CRR Group (excluding insurance company for example). Can you confirm this point ?
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_92 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" et Column 050 "other related parties"
FINREP - Template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" and Column 050 "other related parties" : can you confirm that the column 020 "subsidiaries" includes transactions with "sister entities" ?
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_91 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]"
FINREP - Template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]" : for this row, the ITS refers to "products issued by entities outside the Group" -> Which level of Group has to be considered : Accounting Group (including insurance companies for example) or CRR Group (excluding insurance companies for example) ?
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_90 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts"
FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts" : does the row 170 "liabilities under insurance and reinsurance contracts" include insurance company technical reserves?
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_89 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Contents of template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets"
FINREP - Template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets" : on which row do we have to set amounts linked to "other non financial assets" and reported on row 570 "other" in template 2 ?
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_88 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - F16.7 Impairment on financial and non-financial assets - "Impairment or (-) reversal of impairment of investments in subsidaries, joint ventures and associates" (Rows 070 à 090)
FINREP - Template 16.7 Impairment on financial and non-financial assets - "Impairment or (-) reversal of impairment of investments in subsidaries, joint ventures and associates" (Rows 070 à 090) : in spite of the reference to IAS 28, we presume that the row 080 "joint ventures" anticipates IFRS 11 (with the end of proportionally consolidation). But we don't understand what is expected on the row 070 "subsidiaries" : these one are all fully consolidated and not with the equity method.
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_87 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - Template 16.1 Interest income and expenses by instrument and counterparty sector (+ template 2) - Setting of interests on derivatives - hedge accounting other than interest rate risk
FINREP - Template 16.1 Interest income and expenses by instrument and counterparty sector (+ template 2) - Setting of interests on derivatives - hedge accounting other than interest rate risk : concerning interest on derivatives held for hedge accounting other than interest rate risk, we wonder about their setting: - we understand they are not included in template 16.1 ; can you confirm this point ? - on which row of template 2 "statement of profit or loss" should they be included ? We foresee to include them on row "other assets" (row 080) and "other liabilities" (row 140). Is it correct?
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_86 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP: F14 Fair value hierarchy: financial instruments at fair value - Columns 060 to 080 "Accumulated change in fair value before taxes"
FINREP - Contents of template 14 Fair value hierarchy: financial instruments at fair value - Columns 060 to 080 "Accumulated change in fair value before taxes" : do gains and losses to be reported in columns 060 to 080 include only gains and losses accounted in the statement of profit or loss (like columns 040 and 050) or do they also include gains and losses accounted in "statement of comprehensive statement" ?
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_85 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - F13.1 Breakdown of loans and advances by collateral and guarantees - Col 030 "Other collateralized loans - Cash [Debt instruments issued]"
FINREP - Template 13.1 Breakdown of loans and advances by collateral and guarantees - Col 030 "Other collateralized loans - Cash [Debt instruments issued]" : ITS 81b indicates that Column 030 includes "pledges of debt securities issued by the institution". We don't understand the reference to "debts securities issued by the institution" : an institution secure its loans with securities issued by other issuers but not with its own securities; moreover, CRR Article 197 is referring to debt securities issued by different issuers but not to debt securities issued by the institution. Can you explain this?
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_84 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP: F12 Movements in allowances for credit losses and impairment of equity instruments - Col 020 to 060 - Breakdown by counterparty
FINREP - Template 12 Movements in allowances for credit losses and impairment of equity instruments - Col 020 to 060 - Breakdown by counterparty : the breakdown by counterparty of "variation flows" columns (columns 020 to 060) is heavy - does EBA allow that institutions make this breakdown only on "closing balance" column (col 070) as it tolerates for similar template FIN 30B in current FINREP?
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_83 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - F10 Derivatives - Trading - "Economic hedges" (Rows 020, 080, 140, 200, 260 and 280)
FINREP - Template 10 Derivatives - Trading - "Economic hedges" (Rows 020, 080, 140, 200, 260 and 280) - can you confirm that this row shall include "mechanically" all derivatives classified as "held for trading" in accountancy but that are not part of the trading book as defined in CRR (excepted derivatives for proprietary trading) ?
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_82 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - F8.1 Breakdown of financial liabilities by product and by counterparty sector - "Repurchase agreements" (Rows 100, 150, 200, 250, 300 and 350)
FINREP - Template 8.1 Breakdown of financial liabilities by product and by counterparty sector - "Repurchase agreements" (Rows 100, 150, 200, 250, 300 and 350) - can you confirm that the rows "Repurchase agreement" do not include assets pledged that are not securities?
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_81 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - F7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 310 "project finance loans"
FINREP - Template 7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 310 "project finance loans" : does this row include all "specialised lending exposures" (CRR art 147.8) or only the subcategory "project finance loans" ? Indeed, the European directive 2006-048 (art 86 al 6) mentioned "specialised lending exposures", but in the French version, a breakdown by sub-category had been added : objects lending, commodities lending, real estate financing and project finance loans ?
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_80 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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FINREP - F7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 260 "Advances that are not loans"
FINREP - Template 7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 260 "Advances that are not loans" : does this row include advances in associates current accounts (which are advances and not loans) ?
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_79 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 26/07/2013 |
Date of publication: 14/02/2014
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