Question ID:
2013_562
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - FINREP (incl. FB&NPE)
Article:
99
Paragraph:
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph:
Annex III, F 19.01
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Swedish Bankers' Association
Country of incorporation / residence:
Sweden
Type of submitter:
Industry association
Subject Matter:
Identifying the forborne exposures
Question:

What are the approaches, which are being considered in identifying the forborne exposures, as well as exposures under probation? (i.e. IT, manual). How will the 2 year probation period for the forborne exposures be managed for the exposures which are classified as forborne, and which are no longer non-performing? Are they required to be reported separately within table 18?

Background on the question:

What are the approaches, which are being considered in identifying the forborne exposures, as well as exposures under probation? (i.e. IT, manual). How will the 2 year probation period for the forborne exposures be managed for the exposures which are classified as forborne, and which are no longer non-performing? Are they required to be reported separately within table 18?

Date of submission:
26/11/2013
Published as Final Q&A:
04/04/2014
Final Answer:

The Final Draft ITS on Supervisory reporting on forbearance and non-performing exposures is not prescriptive on the methodologies and approaches institutions may apply to identify forborne exposures, and they remain free to implement those they deem the most appropriate to comply with the requirements in the definition.

As per paragraph 176 (b) to be included in Annex V part 2 of Regulation (EU) No 680/2014 – ITS on Supervisory Reporting of institutionsthe Draft ITS on Supervisory reporting according to EBA Final Draft ITS on Supervisory reporting on forbearance and non-performing exposures, the probation period starts only when a forborne exposure becomes performing. Exposures that are classified as forborne but are no longer non-performing should therefore be reported in column 050 of template F 19.00. In template F 18.00, these exposures should be reported as performing in column 020 as well as in the appropriate column between 030 and 050.

 

*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.

 

DISCLAIMER:

The present Q&A on Supervisory reporting is provisional. It will be reviewed after the respective Implementing Regulation is in force and published in the Official Journal, which may differ from the text of the relevant draft ITS to which it relates.

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