Question ID:
2014_1058
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Large Exposures
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph:
Annex VIII, C 27.00 , C070
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
Concentration risk - type of counterparty
Question:

We understand that the purpose of column 70 in table C27 is to identify institutions/unregulated financial sector entities We understand (EBA 2013-395) that if the parent co of a group of connected clients qualifies as institution (or unregulated financial sector entity), all the clients of the family should be reported be institutions or not, be unregulated financial sector entity or not. --> should all the clients of a group of connected being institutions bear the same type of counterparty in C27 column 70? --> should we fill in the type of conterparty only when the group of connected client institutions/unregulated financial institutions is part of the 10 largest exposures on institutions and/or unregulated financial sector entities

Background on the question:

Unclear guidelines

Date of submission:
08/04/2014
Published as Final Q&A:
30/10/2015
Final Answer:
EBA Q&A 2013_492 determines that a group of connected clients as a whole is classified as institution / unregulated financial sector entity if the parent company (or in the case there is no parent company the most significant client) is an institution / unregulated financial sector entity itself. In Templates C29.00 (LE3) and C 31.00 (LE5) the details of the exposures to individual clients within such a group of connected clients shall be given for each individual client of the group and not only for members of the group that qualify as "institutions" or "unregulated financial sector entities".
 
Within such a group of connected clients every individual client has to be marked as institution (C 27.00 (LE1) c070 = I), unregulated financial sector entity (C 27.00 (LE1) c070 = U) or other client (C 27.00 (LE1) c070 left empty) according to its specific character.
 
The Instructions in Annex IX of Regulation (EU) No 680/2014 - ITS on Supervisory Reporting of institutions (ITS) for C 27.00 c070 state that "The type of the counterparty of the ten largest exposures to institutions and the ten largest exposures to unregulated financial sector entities shall be specified by using "I" for institutions or "U" for unregulated financial sector entities." 
 
This means that in cases other than the 10 largest exposures to institutions and the 10 largest exposures to unregulated financial sector entities, c070 shall be left empty.
Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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