Question ID:
2014_1204
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - FINREP (incl. FB&NPE)
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph:
Annexes III and IV
Disclose name of institution / entity:
No
Type of submitter:
Consultancy firm
Subject Matter:
Is validation rule v3897_s correct and shall be strictly adhered to?
Question:

There are a number of sign validation rules which are applied to the FINREP templates. Are all of them correct and shall be strictly adhered to?

For example, rule v3897_s requires that all items in template F 01.01 (FINREP) are greater or equal to 0. This validation may not be applicable for some of the items in template F 01.01, such as row 250 – 'Fair Value changes of the hedged items in portfolio hedge of interest rate risk'. As this item (row 250) may be a contra-asset account (i.e. reducing the total assets balance), shall it nevertheless be reported as a positive number (as required by the validation rule)?

Background on the question:

There are a number of sign validation rules which are applied to the FINREP templates. Are all of them correct and shall be strictly adhered to?

For example, rule v3897_s requires that all items in template F 01.01 (FINREP) are greater or equal to 0. This validation may not be applicable for some of the items in template F 01.01, such as row 250 – 'Fair Value changes of the hedged items in portfolio hedge of interest rate risk'. As this item (row 250) may be a contra-asset account (i.e. reducing the total assets balance), shall it nevertheless be reported as a positive number (as required by the validation rule)?

Date of submission:
16/05/2014
Published as Final Q&A:
14/10/2016
Final Answer:

The assessment is correct, row 250 of template F 01.01 of Annexes III and IV of Regulation (EU) No. 680/2014 (ITS on Supervisory Reporting) may contain both positive and negative figures.

The same applies to row 250 of template F 17.01, row 250 of template F 20.01, row 160 of template F 01.02, row 160 of template F 17.03 and row 160 of template F 20.02 of Annexes III and IV.

Accordingly, the validation rules v3897_s, v3957_s, v3960_s, v3898_s, v3959_s and v3961_s which are already deactivated and would prevent the reporting of negative values in the respective cells will be amended.

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