Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Annex V, Part 2.63 and 2.80
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
F 09.02 & F 13.01: Maximum amount of the guarantee that can be considered

Please we would like to know what the differences are between the reporting of the "maximum amount of guarantee that can be considered" in templates F 09.02 and F 13.01. Why are these concepts not equal?

In question ID 2013_338 it is stated:

(...) since for F 09.02, the amount is the maximum amount the counterparty could have to pay if the guarantee is called on, and in table F 13.01, the amount of guarantee shall not exceed the carrying amount of the related loan.

Background on the question:

In our opinion question ID 2013_338 states the difference without explaining the criteria in need.

Date of submission:
Published as Final Q&A:
Final Answer:

The concept of “maximum amount of guarantee that can be considered” is the same in templates F 09.02 and F 13.01 of Annexes III and IV of Regulation (EU) No. 680/2014 (ITS on Supervisory Reporting). However, as specified in paragraph 80 of Part 2 of Annex V of the ITS on Supervisory Reporting, the amounts to be reported in F 13.01 are capped at the carrying amount of the related loan.

This means that in those cases where the maximum amount of the guarantee to be called on exceeds the carrying amount of the loan, the amounts reported in F 09.02 and F 13.01 will not match. These cases are expected not to happen very often but prevent an automatic reconciliation between the data points in these two FINREP templates.

Final Q&A
Answer prepared by:
Answer prepared by the EBA.