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:
Draft ITS on Supervisory Reporting of Institutions
Disclose name of institution / entity:
Type of submitter:
Consultancy firm
Subject Matter:
Scope for probation period

Paragraph 176 defines the criteria to discontinue forbearance classification. According to paragraph 176 (b) "...a minimum 2 year probation period has passed from the date the forborne exposure was considered as performing". According to Annex II “EBA ITS 2013 03 Annex I (Annex I ITS FBE NPE Amemdments Annex III ITS reporting IFRS templates)” paragraph 176 (b) is only applicable to table 19 column 50 (of which: Performing forborne exposures under probation). Does this mean that the 2 year probation period is only required for exposures which are reported in column 50 – i.e. exposures with forbearance measures which have been reclassified out of the non-performing forborne exposure columns (see paragraph 180)?

Background on the question:

At the moment it is not clear whether the 2 year probation period is applicable only to forborne exposures that have been reclassified from the non-performing category or generally to all performing exposure with forbearance measures.

Date of submission:
Published as Final Q&A:
Final Answer:
The two years’ probation period is applicable to all forborne exposures, irrespective of whether they were classified as performing or non-performing when the forbearance measures were granted:
a) The probation period applicable to a performing exposure that was not classified as non-performing at the date the forbearance measure was extended or for which the forbearance measures have not led the exposure to be classified as non-performing begins at the date the forbearance measure was granted (paragraph 177);
b) The probation period of a non-performing forborne exposure begins the day the exposure is qualified as performing (paragraph 176).
The rules for non-performing forborne exposures in b) above are applied to performing forborne exposures reclassified out of the non-performing category (paragraph 176) and to forborne exposures reclassified as non-performing in application of paragraph 179, as the application of paragraph 179 interrupts the probation period of a performing forborne exposure (the scope of application of paragraph 179 is further specified in Q&A 2014_736).
Although the probation period applies to all forborne exposures, according to paragraph 180 of Annex V of Regulation (EU) No 680/2014 – ITS on Supervisory Reporting of institutions (ITS), only those performing forborne exposures reclassified from the non-performing category and which are in the probation period (exposures under point b) above) shall be reported in column 050 of F 19.00.
The content of column 050 of F 19.00 is further specified in Q&A 2014_736.
Final Q&A
Answer prepared by:
Answer prepared by the EBA.