Reporting of the net DTA that are dependent on future profitability and arise from temporary differences that are not deducted and will be risk weighted at 250%

For the net DTA that are dependent on future profitability and arise from temporary differences that are not deducted and will be risk weighted at 250%, where should we report the RWA?

Counterparty breakdown

To be able to report the counterparty breakdown in the FINREP tables in Annex III (e.g. F 04.01 - F 04.04) the Swedish sector-/counterparty codes has to be sorted into the FINREP counterparty breakdown according to the instructions in in Annex V, Part 1.35. However, the instructions are not always clear enough. E.g.: Definition of credit institutions: EBA instructions (published 26th July 2013) do not provide complete information on the definition of credit institutions. The definition of credit institutions comprises only banks and multilateral banks. Other types of credit institutions are not mentioned at all in counterparty sector definitions. In March 2012, EBA and ECB developed a joint document bridging between FINREP and BSI (“Bridging the reporting requirements regarding ESCB Balance Sheet and Interest rate statistics with EBA Guidelines on FINREP, COREP and Large exposures”) In this document, all MFIs that are credit institutions (i.e. excluding central banks and money market funds) shall be regarded as credit institutions in FINREP. As referenced by ECB to Directive 2000/28, an MFI Credit institution is either: “an undertaking whose business is to receive deposits or other repayable funds from the public and to grant credits for its own account” “an electronic money institution… on the taking up, pursuit and prudential supervision of the business of electronic money institutions”. Question: Which definition should be used in FINREP? Are credit institutions only banks and multilateral banks or all MFI satisfying the ECB to Directive 2000/28? There is a obvious risk that institutions will make different interpretations with unclear guidance.

How should IRB-institutions exclude exposures according to art 140.4?

Institutions should exclude the exposure classes in art 112 (a) to (f) when calculating the institution-specific countercyclical capital buffer rates. How should this be applied for Institutions that are not using the Standardised approach but IRB approach? It in addition not not clear in the instruction if C0903 should be filled in even though the directive not yet has been implemented in the country. I.e. should C0903 be filled in as per end March 2014, even though an Institution not should report any buffer as per that date?

Financial assets impairment

Where should be reported in the financial reporting forms F 04.04 and F 07.00 the allowances related to individually insignificant financial assets which were not assessed for impairment on individual basis (following the option of IAS 39.64), but were found collectively impaired?

FINREP: F8.1 Breakdown of financial liabilities by product and by counterparty sector

This question ask for a clarification of the Table 8.1 Breakdown of financial liabilities by product and by counterparty sector foreseen by EBA FINAL draft implementing Technical Standards 2013-02, Anex III – reporting financial information according to IFRS. It is not clear which accounting portfolios based on IFRS (Held for trading, Designated at fair value through profit or loss, Amortised cost) are required to be included in an column 050 “Amount required to pay at maturity”.

FinRep table 5 row 010 column 030 - On demand [call] and short notice [current account]

Annex V indicates that balances receivable on demand classified as "cash and cash balances at central banks" shall also be reported in this template. This statement is supported by the validation rules stating that {F 01.01, r040, c010} = {F 5.00, r010, c030} (though only relating to other demand deposits). However, amounts in table 5 should be equal to tables 4.1 through 4.4 regarding loans and advances. This reasoning is indirectly supported by the following logical reasoning: If {F 01.01, r040, c010} = {F 5.00, r010, c030} AND if {F 01.01, r040, c010} has a detailed breakdown in table 4 as stated in Annex III, then there should be a link between table 4 and { F 5.00, r010, c030}. In which table (4.1, 4.2, 4.3, 4.4) should cash and cash balances be included? Validation rules regarding these templates don't seem to include cash and cash balances at central banks.

Financial guarantees received reported in table 9.2 and table 13.1

Should Financial Guarantees recieved reported in table 13.1 equal financial guarantees in table 9.2?

IFRS references of column 110 “Accumulated write-offs” of F 07.00 template

What is the meaning of the references to IAS 39 AG 84-92 provisions (related to impairment losses) in the column 110 of F 07.00 template?

Allocation of the collective impairment allowances

In order to fill in the FINREP templates, how should be performed the allocation of the collective impairment allowances among group assets?