According to the Final Q&A 2013_619 (posted on 30/04/2014), ‘information submitted… referring to a certain period shall be reported cumulatively from the first day of the accounting year to the reference date’, ‘the FINREP templates should be reported on a cumulative basis’.
However, the Final Q&A 2013_158 (posted on 14/02/2014), talking about ‘Amount of cumulative change in fair values’, says that ‘Retrospective application back to the date of initial acquisition’ or ‘to apply the requirements retrospectively from the earliest period practicable’.
We also saw a reference about certain period in Annex V, Part 2, paragraph 86 of the ITS on Supervisory Reporting that made us doubt: ‘Change in fair value for the period shall include gains or losses from re-measurements of the instruments in the period’.
Having these three different alternatives about reporting period’s calculation, which option would be the most appropriate to apply on ‘Amount of cumulative change in fair values’?
Problems to differentiate certain reporting periods
As a general rule, Q&A 2013_619 is applicable to the reporting of information referring to a certain period saying that the information pursuant to the templates of Annex III and IV to Regulation (EU) No. 680/2014 (ITS on Supervisory Reporting) has to be reported on a cumulative basis from the first day of the accounting year to the reference date.
In particular, this general rule applies to the amounts reported in columns 040 and 050 of template F 14.00 of Annexes III and IV. In addition, Annex V, Part 2, paragraph 86 provides further instructions on these columns: ‘‘Change in fair value for the period’ shall include gains or losses from re-measurements in the period of the instruments that continue to exist at the reporting date. These gains and losses are reported as for inclusion in the statement of profit or loss; thus, the amounts reported are before taxes.’
For columns 060, 070 and 080 of template F 14.00, the changes in fair value which are shown refer to multiple periods. Annex V, Part 2, paragraph 87 provides the explicit guidance that ‘Accumulated change in fair value before taxes’ shall include the amount of gains or losses from re-measurements of the instruments accumulated from the initial recognition to the reference date, as it is also stated in Q&A 2013_158.