We have found differences between the package provided by our XBRL suppliers and those supplied by EBA mainly with regards to geographical breakdown.The problem is regarding total sheets whether these should be included or not and the list of countries that should be reported in the respective sheets. Our XBRL suppliers suggested we contact EBA for further clarification as the instructions and the reference ( please see link below) made in the instructions to Article 96 of the CRR are not clear. The EBA Q&A questions already submitted which refer to geographical breakdown deal mainly with threshold issue, while we need clarifications regarding the list of countries and total sheets. http://www.eba.europa.eu/documents/10180/603236/Draft---ITS-on-reporting... For example for table C 15.00 : Extract from Annex IV found in the above link states: “3. Geographical breakdown 9.11. According to Article 96 paragraph 1 second sentence of CRR this template is reported for separately for each property market within the EEA to which the relevant institution is exposed to.”
Instructions are not clear.
C 09.01 and C 09.02 (CR GB 1 and CR GB 2)
According to Annex II point 79 of the Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS), "institutions fulfilling the threshold set in Article 5 (a) (4) shall submit information with geographical breakdown regarding the domestic country as well as any non-domestic country". Totals do not have to be submitted.
According to Q&A 143 exposures to supranational organisations shall be assigned to the geographical area "other countries". Until the DPM and taxonomy are amended exposures should be assigned to "Cook Island".
C 09.03 (CR GB 3)
According to Annex II point 84 of the ITS on reporting, C 09.03 shall be reported for each country the institution is exposed to. No total sheet is required.
C 15.00 (CR IP LOSSES)
Annex VII point 10 of the ITS on reporting states:
"Following the reporting scope, the CR IP Losses reporting shall consist of the following templates:
a) one total template
b) one template for each national market in the Union where the institution is exposed to, and
c) one template aggregating the data for all national markets outside the Union where the institution is exposed to".
Currently a template aggregating the data for all national markets outside the Union is not available in the DPM and also not part of the XBRL taxonomy provided by EBA. Therefore on a voluntary basis, institutions may submit country by country data for non-EU countries (instead of aggregated data) until the DPM and the taxonomy are amended accordingly.
C 21.00 (MKR SA EQU)
According to Annex II, point 137, the template has to be filled out separately for the "total" plus a static, pre-defined list of countries (see there for the complete country list).
Until Annex I, II and the DPM is amended, in the light of the RTS on the definition on market (Commission Delegated Regulation 525/2014), institutions are requested to report the own funds requirements for general risk of market 'euro area' (Art. 1 (a) of the Delegated Regulation 525/2014) in the "Total" template as well as in one of the euro area country templates, i.e. the country where the institution reports C 21.00 to the competent authority.