How should non-performing non-renewable loans be reported in the template C 60.00? Should they be reported in rows 900-1250 i.e. 'non-renewable loans and receivables' or row 1300 'any other assets', and what maturity bucket should they be assigned to?
Annex XIII to Draft ITS on Supervisory Reporting (paragraph 2.1.(2)) states that 'All assets reported on an institutions balance sheet shall be reported here' and also (paragraph 2.1.(3)(iii)) 'Assets shall be reported according to their residual contract maturity and not behavioural assumptions'. Art. 428(2) of CRR reads 'Where applicable, all items shall be presented in the five buckets described in Article 427(2)', so one could argue that the split between maturity buckets is not applicable for NPLs. Therefore it is unclear how NPLs should be treated, especially as it might be the case that the contractual maturity of such loans has already passed.
In the template C 60.00, non-performing loans shall be reported in row 1300 "any other assets" in the "After 12 months" bucket.
Where the loans have been restructured (i.e. the institution and the client have modified their original agreement to reschedule payments), amounts due as partial repayments shall be reported in the appropriate row according to their characteristics and in the appropriate maturity time bucket.