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Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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 III, F 40.01 column 010
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Missing Entity code

What should be reported in column 020 in table F 40.01 Annex III , if entity code is missing for an entity? Should the cell be left empty, if an LEI code is existing for the entity?

Background on the question:

The entity code should be a valid MFI code from the ECB MFI list. However, MFI codes could be missing for some of our consolidated subsidiaries as they do not fall under the definition of an MFI as they do not perform banking activities. Also, the corresponding National Central Bank has not allocated them a national ID code. We propose to leave the column empty for those entities where the code is missing, provided a valid LEI code is reported in column 010 as the latter would meet the identification needs.

Date of submission:
Published as Final Q&A:
Final Answer:
According to the definitions of the DPM, column 020 of Template F 40.01 of Annex III of Regulation (EU) No 680/2014 - ITS on Supervisory Reporting of institutions (ITS) is defined as "key value". The "key value" is a unique row identifier and must be reported.
If only the LEI code is available, it should be reported in columns 010 (LEI code) and 020 (Entity code).
There may be cases where a group entity does not have an LEI code, either because the global LEI system is not yet fully operational or due to the entity not being a party to a financial transaction.
As noted in EBA Q&A 2013_333, when the LEI (or pre-LEI) code of the investee is missing and cannot be used as a substitute for a missing MFI code in {F 40.01, c020}, the data point should be populated with an alternative code used to identify the investee (e.g. national identification code).
Final Q&A
Answer prepared by:
Answer prepared by the EBA.