According to the Article 395 paragraph (5) point a) of CRR the limit to large exposure may be exceeded for the exposures on the institution's trading book – among others - if the exposures on the non-trading book do not exceed the limit laid down in paragraph (1). How shall the excess of limit to the large exposure on the non-trading book after CRM be reported in the CA2 template?

Previous years this excess was covered with own funds in the Hungarian prudential regulation.

According to the substantive provisions on large exposures the breach of the large exposures limit is an exceptional case. As response to an exceptional breach Article 396 (1) of the Regulation (EU) No. 575/2013 (CRR) determines two legal consequences. Firstly, the institution shall report the breach. Secondly, regarding the scope for action of the competent authority, it may, where the circumstances warrant it, allow the institution a limited period of time in which to comply with the limit. However, in the specific case of exposures arising in the trading book, the CRR allows the large exposures limit to be exceeded for a short time only under certain conditions and if the excess is reported, see Article 395 (5) of CRR.

Regarding the reporting of both of the above described breaches of the large exposures limit the Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions does not contain a template for these cases, neither in the templates for reporting large exposures (annex VIII), nor in the templates for reporting own funds and own funds requirements (annex II). This is against the background that the reporting of breaches of the large exposure limits is not mentioned in the mandate of Art. 394 (4) of CRR. Hence, in these cases, an institution shall notify without delay the competent authority of the breach according to Art. 396 (1) or Art. 395 (5) last sentence of CRR.