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.
The Financial Reporting templates (FINREP), Annex III, have several templates where the institutions are supposed to specify breakdown into different counterparty groups, e.g. templates F 04.01 - F 04.04. Instructions to the counterparty breakdown are in Annex V, Part 1.35.
For the purpose of FINREP counterparty breakdowns, a credit institution is any institution covered by the definition contained in Article 4(1) of Regulation No 575/2013 ( "undertaking whose business is to receive deposits or other repayable funds from the public and to grant credits for its own account") and multilateral banks. Therefore, its scope is not restricted to banks and multilateral banks as the current text of paragraph 35(c) in Part 2 of Annex V of the
ITS on Supervisory reporting may lead. FINREP instructions shall be amended accordingly in next available version of the ITS.
The regulatory provisions that govern the statistical reporting of the ECB (BSI Regulation) also refer to the CRR as regards the definition of credit institutions. However, the MFI category is broader than the sole credit institutions and includes, in addition to credit institutions, other institutions with liabilities included in the ECB 19s definition of broad money (M3) as central banks, money market funds and other financial institutions with monetary liabilities including issuers of electronic money.
*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.