Do loans collateralized by immovable property in template F 05.00 contain only residential and commercial immovable property, like in F 13.01, or are they open to other collateralized immovable property (those which do not meet the definition of residential and commercial provided by CRR)? If the former, are those loans collateralized by other immovable property reported as other loans collateralized?
There are loans which are collateralized by immovable property which does not meet the definition of residential and commercial as given in CRR (for example, a residence which is not occupied by the owner) and we do not know whether there must fall within the category loans collateralized by immovable property. Row 090 of template F 05.00 requires information by counterparty on loans collateralized by immovable property. Template F 13.01 of FINREP contains a breakdown of loans collateralized by immovable property which only considers two possible values: residential and commercial (columns 010 and 020). We are not sure whether we must also understand that in template F 05.00 only residential and commercial immovable property is to be considered. Annex V of the ITS on supervisory reporting does not clarify the issue. In the instructions to template F 13.01 (paragraph 81 of Part 2) it is said that 1cFor reporting loans and advances according to the type of pledge the following definitions shall be used: (a) within 1cMortgage loans [Loans collateralised by immovable property] 1d, 1cResidential 1d includes loans secured by residential immovable property and 1cCommercial 1d loans secured by pledges of commercial immovable property; in both cases as defined in the CRR. (b) within 1cOther collateralised loans 1d, 1cCash [Debt instruments issued] 1d includes pledges of deposits in or debt securities issued by the institution, and 1cRest 1d includes pledges of other securities or assets. 1d. Therefore, loans collateralized by immovable property seem to be limited to commercial and residential immovable property. Instructions of template F 05.00 (paragraph 41.h and i of Part 2) leave this open as they state that: 1c(h) 1cMortgage loans [Loans collateralized by immovable property] 1d include loans formally secured by immovable property collateral independently of their loan/collateral ratio (commonly referred as 1cloan-to-value 1d). (i) 1cOther collateralized loans 1d include loans formally backed by collateral, independently of their loan/collateral ratio (so-called 1cloan-to-value 1d), other than 1cLoans collateralised by immovable property 1d, 1cFinance leases 1d and 1cReverse repurchase loans 1d. This collateral includes pledges of securities, cash, and other collateral. 1d. The definition of loans collateralized by immovable property is not restricted in this case to commercial and residential immovable property.
Loans collateralized by immovable property in template F 05.00 of Regulation (EU) No 680/2014 – ITS on Supervisory Reporting (ITS) consist of loans secured by residential and commercial immovable property, like in F 13.01. Any immovable property that does not fulfil the definition of residential property in Article 4(1) (75) of Regulation (EU) No. 575/2013 (CRR) is considered as commercial immovable property. Consequently, a third category of immovable property does not exist.
If the immovable property is pledged as collateral and independent from its eligibility for the purposes of Part 2, Title II, chapter 4 of CRR, the immovable property respectively the loan secured by it are reported in F 13.01 respectively F 05.00 in the item ‘Loans collateralised by immovable property’. Both in F 05.00 and F 13.01, ‘other collateralized loans’ must not include any loans secured by immovable property collateral.