Should the loans reported in C 60.00, rows 1260 and 1270 be reported in full regardless of the value of the real estate collateral, or only up to the value of the collateral?
Article 428(1)(h) of CRR refers to loans collateralised by real estate. However it is not clear wherher a loan with a value higher than the underlying collateral (i.e. LtV>100%) should be reported in full, or should it be reported in rows 1260 and 1270 only up to the value of the collateral. As an example, consider a loan with an outstanding amount of 100 000 EUR, collateralised by a residential real estate that is currently worth 80 000 EUR. In such a case, should the total amount reported in row 1270, columns 010-050, be 80 000 EUR or 100 000 EUR?
Non-renewable loans and receivables shall be reported in row 900 – 1250 of template C 60.00 of Annex XII to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) in accordance with Article 428 (1)(g) of Regulation (EU) No 575/2013 (CRR). Of these non-renewable loans and receivables, those collateralized by real estate shall, in addition, be reported in template C 60.00, rows 1260-1280 in accordance with Article 428 (1)(h) CRR. The loans reported in rows 1260-1280 shall only be reported up to the value of the collateral.
In the example given in the question, this corresponds to reporting 80.000 EUR in row 1270 of template C 60.00 and EUR 100.000 in the relevant rows 900-1250 thereof.