Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Draft ITS on Supervisory Reporting of Institutions
Annex V.Part 2.157, Annex V.Part 2.172(a), Annex V.Part 2.180
Disclose name of institution / entity:
Name of institution / submitter:
Country of incorporation / residence:
Type of submitter:
Consultancy firm
Subject Matter:
Forborne exposures, Template 19, column 110

Column 110 of Template 19 provides references to Annex V.Part 2.157 and Annex V.Part 2.172(a). Our understanding is that this column requires disclosure of exposures with forbearance measures, that would otherwise be classified as performing but have not met all of the additional exit criteria extended to non-performing exposures with forbearance measures as defined in Annex V.Part 2.157 (e.g., the exposure is no longer classified as defaulted or impaired and there are no past due amounts, but only 8 months have passed since forbearance measures were extended and therefore it should remain to be classified as non-performing). We believe that the intent is to show those exposures that are performing better after the forbearance measures were extended and would be classified as performing if there were no additional exit criteria set out by Annex V.Part 2.157. Can you please confirm if this is a valid interpretation or different information is required to be reported in this column?

Background on the question:

Column 110 “of which: forbearance of non-performing exposures” of Template 19 is a subset of Column 60 “non-performing exposures with forbearance measures”. References provided for this column refer to Annex V.Part 2.157 that set out conditions when non-performing exposures to which forbearance measures were extended may be considered to have ceased being non-performing and Annex V.Part 2.172(a) that states that the situation when “a modified contract was classified as non-performing or would in the absence of modification be classified as non-performing“ shall be treated as forbearance measure. Furthermore, Annex V.Part 2.180 states that “Exposures to which paragraph 157 applies shall be separately identified in the column “of which: forbearance of non-performing exposures”.

Date of submission:
Published as Final Q&A:
Final Answer:

In accordance with paragraph 180 of Annex V of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS), column 110 of F 19.00 Template shall contain data about exposures that were non-performing prior to the extension of forbearance measures and which are still non-performing at the reporting date according to paragraph 157.

In contrast, column 60 of F 19.00 Template ("Non-performing exposures with forbearance measures") shall include all non-performing exposures with forbearance measures as defined in paragraph 180.

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