Question ID:
2014_1419
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - COREP (incl. IP Losses)
Article:
99
Paragraph:
n.a.
Subparagraph:
n.a.
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph:
Annex II, paragraph 3.2.5., row 030
Disclose name of institution / entity:
No
Type of submitter:
Competent authority
Subject Matter:
Row 030 C07.00 reported also for exposure class of protection provider
Question:

Should the part of the "eligible" SME exposure according to Article 501 CRR that is secured with e.g. guarantee be reported in the row 030 (C07.00) in the exposure class of the guarantor and also be subject to the supporting factor?

Background on the question:

According to the final Q&A 2013_565 the eligible SME exposures according to Article 501 CRR should always be included either in the retail or in the corporate or secured by mortgages on immovable property classes irrespective of whether CRM techniques with substitution effects (e.g. guarantees) are reclassified for reporting purposes to another exposure class. This means that, for example, part of the SME corporate loan subject to supporting factor that is secured with bank guarantee is reclassified to the exposure class of institutions and therefore should be reported in row 030 (of which: SME subject to the SME supporting factor) and RWA (column 220) should be decreased for the supporting factor.

Date of submission:
05/08/2014
Published as Final Q&A:
02/10/2015
Final Answer:
According to Q&A 2013_565, the supporting factor treatment applies to positions irrespective of whether or not CRM with substitution effects were applied. In other words, while CRM techniques with substitution effects can lead to exposures being reassigned to another exposure class for reporting purposes, this does not mean they are excluded for the purposes of the SME supporting factor treatment.
 
With regard to the example given in the question, the part of the exposure which is secured by a guarantee is reassigned to and reported in the exposure class of the protection provider. In accordance with point 44 of Annex II of Regulation (EU) No. 680/2014 - ITS on Supervisory reporting, this implies that the respective part of exposure is also reported in row 030 of that exposure class from column 100 in C 07.00 onwards. The unsecured part remains in one of the exposure classes retail, corporates or secured by mortgages on immovable property. Both parts of the exposure are weighted with the SME Supporting Factor to calculate the risk weighted exposure amounts.
Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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