Question ID:
2013_346
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 (as amended)
Article/Paragraph:
Annex I, C07.00 (rows 220-250)
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Swedish Bankers' Asscoiation
Country of incorporation / residence:
Sweden
Type of submitter:
Industry association
Subject Matter:
Memorandum items in credit risk SA
Question:

Can you please confirm that the memorandum items in row 290-320 only should be filled in within exposure classes mentioned under point 54 (annex II, 3.2.1) and the Total template? I.e. that those rows should be empty in the exposure classes “in default” and "secured by immovable property”.

Background on the question:

The memorandum items in C07.00 should, according to point 54 and 56 in the instruction, only be reported in the six exposure classes that are specified. Exposure class “in default” is not mentioned among those six exposure classes. However, in the example in point 57 it is written that row 220 (which is one of the rows in the memorandum items: “exposures secured by  mortgages on commercial immovable property”) should be filled in on row 220 both in exposure class “Institution” as in exposure class “in default”. This seems contradictory to point 54 and 56.

Date of submission:
07/10/2013
Published as Final Q&A:
07/03/2014
Final Answer:

As explained in paragraph 54 of the CR SA instructions (Annex II, 3.2.2 of the Regulation (EU) No 680/2014 13 ITS on supervisory reporting ofinstitutionsDraft ITS on Supervisory reporting), the memorandum items shall only be reported for the 6 exposure classes: 'Central governments or central banks ', 'Regional governments or local authorities ', 'Public sector entities ', 'Institutions ', 'Corporates ' and 'Retail '. They shall also be reported in the CR SA total template. Memorandum items rows should be empty in the exposure classes "in default " and "secured by immovable property ".

 

*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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