How shall off-balance sheet exposures be reported in first FINREP reports if the data is not available in the accounting systems? Can a starting date for collecting this dta be set?

Information about commitments, guarantees etc. received is not collected in the banks’ accounting systems. On this basis it would be most helpful if a starting date could be set.

Banks must have data about their off-balance sheet exposures for determining the capital charges for off balance sheet exposures (Article 111 of the Regulation (EU) No 575/2013 13 CRR) and for meeting the disclosure requirements in IFRS 7.36. If the data are not in the accounting systems banks have to implement these data into their reporting systems and report them as specified in the Regulation (EU) No 680/2014 13 ITS on supervisory reporting of institutionsDraft ITS on Supervisory reporting.

*As of 1/8/2014 the content of this answer was modified to reflect the publication of the final ITS on supervisory reporting of institutions in the Official Journal of the European Union. As a result, the references to the ITS were updated and the disclaimer deleted. For reasons of transparency, revisions are highlighted in track changes.