In the report CR SEC DET, C14.00, the ITS clearly says that column 290 and 300 must written according to the following format : MM/YYYY In the taxonomy published in december those cells are defined as DATE. The problem here is that many of our customers only collect Month and Year for those columns in their information system, but not the day as it was not required first. And as far as i know, in the taxonomy a DATE information muste have a Day to be valid (year and month are not sufficient) => Will you keep those fields as date? if so, is it possible to send those fields with a fixed day?
290 FIRST FORESEEABLE TERMINATION DATE The likely termination date of the whole securitisation in the light of its contractual clauses and the currently expected financial conditions. Generally, it would be the earliest of the following dates: (i) the date when a clean-up call (defined in Article 242(2) of CRR) might first be exercised taking into account the maturity of the underlying exposure(s) as well as their expected pre-payment rate or potential re-negotiation activities; (ii) the date on which the originator may first exercise any other call option embedded in the contractual clauses of the securitisation which would result in the total redemption of the securitisation. The month and year of the first foreseeable termination date shall be reported according to the following format: ‘mm/yyyy’. 300 LEGAL FINAL MATURITY DATE The date upon which all principal and interest of the securitisation must be legally repaid (based on the transaction documentation). The month and year of the legal final maturity date shall be reported according to the following format: ‘mm/yyyy’.
The fields will be kept with the metric "date", which must include a day to be valid. The day to be reported should be the exact day if this data is available, otherwise the day to be reported should be the first day of the month. This principle will be included and the format 'MM/YYYY' will be removed in the instructions of columns 290 and 300 of C 14.00 Template (CR SEC Details ) in the next available version of the ITS on Supervisory Reporting of institutions.