Should increase of credit risk adjustment (specific loan loss provision for credit risks) during reporting period be reflected in the reported data? Should estimated loss be reported (reporting date 30.06.2013) as 250 000 EUR or as 290 000 EUR?
According to Annex VII 13. (c) as losses shall be reported only for exposures having defaulted during the reporting period, changes to losses of exposures having defaulted during previous reporting periods will not be reflected in the reported data. e.g. Date of default 30.04.2013, exposure fully and completely secured Estimated loss as of 30.04.2013 = 250 000 EUR Estimated loss as of 31.05.2013 = 280 000 EUR Estimated loss as of 30.06.2013 = 290 000 EUR
According to Article 12(1) of the
Draft ITS on Supervisory reporting (ITS), C 15.00 template (CR IP Losses) shall be reported with a semi-annual frequency, so the reporting period equals 6 months. As specified in paragraph 13(c) of Annex VII of the ITS (Instructions for reporting losses stemming from lending collateralised by immovable property), losses shall be reported only for exposures having defaulted during the reporting period of 6 months and changes to losses of exposures having defaulted during previous reporting periods (i.e. before those 6 months) shall not be reported in C 15.00 template. Paragraph 13 a) of the instructions of CR IP Losses clarifies that losses should be reported for all defaults [ 26] that occur during the respective reporting period which includes loss estimates.
Considering those provisions, the amount of estimated loss of the example to be reported in the template is the estimated loss at the reporting reference date: 290.000 EUR.
*As of 1/8/2014 the content of this answer was modified to reflect the publication of the final ITS on supervisory reporting of institutions in the Official Journal of the European Union. As a result, the references to the ITS were updated and the disclaimer deleted. For reasons of transparency, revisions are highlighted in track changes.