Question ID:
2013_309
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - COREP (incl. IP Losses)
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph:
Annex II, C 07.00, C 08.01 & C 08.02
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
Reporting SME-supporting factor as an 'of which' of SMEs
Question:

Within the COREP templates, the SME supporting factor (Article 501) is shown as a subset of the SMEs (general). This is reinforced by the validation rules within the DPM. Given SME(general) has a <250 person criteria and the SME-supporting factor doesn't how is this reported?

Background on the question:

The EC recommendation 2003/361/EC 6 May 2003 DEFINITION OF MICRO, SMALL AND MEDIUM-SIZED ENTERPRISES ADOPTED BY THE COMMISSION is the recommended definition of SME (general) within the EBA Q&A No. 2013_27 and is directly referenced under Article 501(2)(d) of the CRR and Article 13092) of the CRD. This recommendation has 3 criteria under Article 2: 1. employ fewer than 250 persons; and 2. which have an annual turnover not exceeding EUR 50 million; and/or 3. an annual balance sheet total not exceeding EUR 43 million For exposures to receive the SME-supporting factor Article 501(2)(b) states among the criteria listed in Article 2 of EC recommendation 2003/361/EC 6 May 2003 only the annual turnoverover shall be taken into account.

Date of submission:
30/09/2013
Published as Final Q&A:
21/03/2014
Final Answer:

Q&A 2013_27 clarifies that for the purpose of Article 501 of Regulation (EU) No 575/2013 (CRR) the SME-definition of that article shall be used (SME/SF). Q&A 2013_27 continues by stating that for the identification of SMEs as counterparts for the purposes of other articles of the CRR, Recommendation 2003/361/CE of 6 May 2003 provides guidance to the institutions.

Depending on the criteria for defining SME chosen by the institution for the CRR (except Article 501), the definition of SME may differ from that in Article 501. As a consequence, the rows/dimensions "SME subject to SME supporting factor " are an "of which " of the Total, not an "of which " position of the row "of which: SME " in the templates included in Annex I of the Regulation (EU) No 680/2014 13 ITS on supervisory reporting of institutionsITS on Supervisory reporting.

According to this interpretation, further amendments in Annex I of the ITS shall be included in the next available version of the ITS and affected validation rules corrected shall be included in the next available version of the ITS.

 

*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.

Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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