Question ID:
2015_1722
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Asset Encumbrance
Article:
100
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph:
Article 2, Paragraph 3
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Central bank of Ireland
Country of incorporation / residence:
Ireland
Type of submitter:
Competent authority
Subject Matter:
Asset Encumbrance Reporting for firms with Accounting Reference Date other than 31 December
Question:

Article 2(3) of the ITS on Supervisory Reporting allows the uniform reporting and remittance dates for reporting financial information (i.e. FINREP) to be adjusted where institutions are permitted by national laws to report their financial information based on their accounting year-end which deviates from the calendar year (this was also clarified in the response to Q&A 147). The supervisory reporting templates on Asset Encumbrance follow, from a methodological point of view, FINREP and the current ITS also includes some cross validation checks between certain data points in FINREP and the AE templates.

In this regard, can the same flexibility with the reporting and remittance dates (in Article 2(3) of the ITS on Supervisory Reporting) provided to institutions that have an accounting year-end which deviates from the calendar year in terms of reporting FINREP also be extended to the reporting of the Asset Encumbrance templates?

Background on the question:

Some banks which report their financial information based on their accounting year-end which deviates from the calendar year have queried whether the same flexibility permitted under Article 2(3) of the ITS on Supervisory Reporting in terms of the reporting and remittance dates for FINREP should also be extended to the Asset Encumbrance templates. The asset encumbrance templates are based on accounting values (carrying amounts) in order to ensure the possibility of reconciling the reported figures with the balance sheet items (FINREP). In this regard, it makes sense that the same reporting and remittance dates applied to FINREP returns are also applied to the Asset Encumbrance templates

Date of submission:
15/01/2015
Published as Final Q&A:
04/08/2017
Final Answer:

According to Article 2(3) of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), where reporting institutions are permitted by national laws to report their financial information based on their accounting year end which does not coincide with the calendar year, they may adjust their reporting reference dates accordingly.

This discretion to adjust the reporting reference dates is only available for financial information (FINREP, Annexes III, IV and V) and, thus, shall not be applied to other parts of the ITS on Supervisory Reporting such as own funds requirements (COREP, Annexes I and II) or assets encumbrance (Annexes XVI and XVII).  

Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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