From the paragraph 49 of Part 2 of Annex V of the Draft ITS on Supervisory reporting and the answer to the question 2013_202 it is clear, that accumulated written-off amounts shall be reported in F 07.00 until the total extinguishment of all the institution's rights (by expiry of the statute-of-limitations period, forgiveness or other causes) or until recovery. Does the same principle hold for the COREP tables C09.01 (columns 060, 070)?

From the paragraph 49 of Part 2 of Annex V of the Draft ITS on Supervisory reporting and the answer to the Q 2013_202 it is clear, that accumulated written-off amounts shall be reported in the FINREP until the total extinguishment of all the institution's rights (by expiry of the statute-of-limitations period, forgiveness or other causes) or until recovery. However, from the COREP instructions in Annex II it is not clear if the same principle should be applied for capital adequacy reporting purposes as well. We would like to draw your attention, that application of this principle for COREP influences the capital adequacy of the bank, because fully written-off amounts might be subject to calculations laid down in the Article 159 of the CRR. Considering the fact, that COREP and FINREP definitions should be consistent and the fact that in the Annex II of the ITS on supervisory reporting, C09.01 column instructions refer to accounting rules (IFRS), we would presume that concept of write-off reporting, defined in the paragraph 49 of Part 2 of Annex V of the Draft ITS on Supervisory reporting, should be used for FINREP and COREP in a consistent manner. N.B. We understand, that according to Q 2013_347, column 060 is filled for defaulted and undefaulted exposures and 070 is filled only for the defaulted ones.

In templates C09.01 and C09.02 all positions are reported which according to Art. 92 (3) (a) CRR are subject to the calculation of risk-weighted exposure amounts for credit risk and dilution risk according to  Part Three Title II and Article 379 of Regulation (EU) No 575/2013 (CRR). The write offs (which are not considered in the calculation of risk-weighted exposure amounts) related to these positions are included in column 0060 of C09.01 and C09.02.