Question ID:
2014_1665
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Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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:
Validation rules DPM 2.1 and DPM 2.2
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Swedish Bankers' Association
Country of incorporation / residence:
Sweden
Type of submitter:
Industry association
Subject Matter:
Inconsistencies in FINREP validation rules for Allowances and provisions for impaired debt instruments, defaulted guarantees and defaulted commitments (F31.01)
Question:

Validation rule v3974_s, says that in F31.01 row 130- Allowances and provisions for impaired debt instruments, defaulted guarantees and defaulted commitments [To be replaced by "Accumulated impairment, accumulated changes in fair value due to credit risk and provisions on non-performing exposures" when reporting of non-performing exposures would be final], should be reported with positive signs. Should row 130 include this rule of positive sign? We consider it should be able to report also with negative signs, for example instruments with amortised cost or FVO. v3974_s 2.0 (2013/09) Sign F 31.01 (020;030;040;050;060;070;080;090;100;110;120;130) (010;020;030;040;050)

Background on the question:

Inconsistencies in the validation rules. Information required for mapping of FINREP data points

Date of submission:
05/12/2014
Published as Final Q&A:
26/06/2015
Final Answer:
The FINREP framework follows a sign convention based on a credit/debit convention which is explained in Annex V, Part 1 paragraphs 9 and 10 of Regulation (EU) No 680/2014 - ITS on Supervisory reporting. The use of sign convention is also clarified in Q&A 2034.
 
F31.01 row 130 (Annex III, IV of Regulation (EU) No 680/2014) should cover "Accumulated impairment, accumulated changes in fair value due to credit risk and provisions on non-performing exposures". Accumulated impairments are reported with a negative sign, provisions are reported with a positive sign and fair value changes due to credit risk can have both signs. However, since row 130 covers only non-performing exposures it is not expected that accumulated changes in fair value due to credit risk would be positive (accumulated gains). The reporting should be done in the following way to allow right sign convention but avoid netting of provisions (which have a positive sign) against impairments (which have a negative sign).
 
On non-performing exposures:
 
Accumulated impairments (negative sign)
 
+ provisions x (-1) (positive sign changed to negative)
 
+ accumulated changes in fair value due to credit risk (gains are positive, losses negative)
 
= Accumulated impairment, accumulated changes in fair value due to credit risk and provisions on non-performing exposures
 
The result will have either negative or positive sign depending on amount of positive fair value changes due to credit risk.
 
For example
Accumulated impairments of -150
Provisions of 35
Accumulated changes in fair value due to credit risk of -45
 
-150 +(35*(-1)) - 45 = -150 13 35 13 45 = -230 to be reported in F31.01 row 130
 
Validation rule v3974_s has been deactivated and will be amended to exclude row 130.
Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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