In case a bank has to provide financial information according to FINREP on a subconsolidated level, but the institution has no accounting obligation on a subconsolidated level, what should be filled in Template 17 of the FINREP-Reporting?
Subsidiaries of Banks in a country different than the country of the main institution, that have own financial subsidiaries, are required to report FINREP on a subconsolidated level. But being a regulatory subgroup does not mean, that accounting wise the subgroup has to make a subconsolidated accounting statement and subconsolidated P/L. In that case no accounting consolidation scope exists.
F 17.00 template aims to collect the FINREP balance sheet with the scope of consolidation used in the audited financial statements. When the institution is not required to elaborate a consolidated (or subconsolidated) balance sheet for audit purposes, it is not required either to elaborate this template. However, when the institution is required to elaborate a consolidated (or subconsolidated) audited balance sheet with a frequency lower than quarterly, it should submit F 17.00 template with quarterly frequency as established in Article 9(a) of the
Draft ITS on Supervisory reporting (ITS).
The ITS does not require institutions to put in place the processes for preparing the balance sheet with the accounting scope when they have no legal obligation to do so. However, once the institution has these reporting processes in place, it should adapt them to be able to submit F 17.00 with quarterly frequency.
*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.