Question ID:
2015_2046
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Funding Plans
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
Article/Paragraph:
template P 01.02, validation rule v4421_s
Disclose name of institution / entity:
No
Type of submitter:
Competent authority
Subject Matter:
Validation rule v4421_s does not comply with validation rules v4117_m, v4118_m, v4119_m, v4120_m as it implies a negative sign for maturing long term funding
Question:

Validation rule v4421_s implies that maturing long term funding must be reported with a negative sign for different categories of long term funding in row (200,230, 260,290,320) and column (020,030,040,050) in template P 01.02. However, this contradicts with validation rules v4117_m, v4118_m, v4119_m and v4120_m.

Background on the question:

Validation rule v4421_s implies that maturing long term funding must be reported with a negative sign for different categories of long term funding in row (200,230, 260,290,320) and column (020,030,040,050) in template P 01.02. However this contradicts with the following validation rules: v4117_m, v4118_m, v4119_m and v4120_m. These validation rules state that long term funding at time t+1 = long term funding at time t - maturing long term funding at time t+1 + issuances of long term funding at time t+1. According to these validation rules, maturing long term funding at time t+1 will be added in stead of subtracted if validation rule v4421_s is applied. The fictive examples in the attached file show that long term funding will differ considerably depending on whether validation rule v4421_s is applied (as in example 1) or not (as in example 2). Reporting positive numbers only in funding plan templates is in line with a previous QA regarding the sign convention for LCR and stable funding reporting (QA 2014_971). As stated in QA 2014_971 "Outflows should be reported as positive figures (...) Furthermore all figures according to Annex XII (Reporting on Liquidity, Templates C 51.00, C 52.00, C 53.00, C 54.00, C 60.00 and C 61.00) of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions have to be reported positively. This is because of the DPMs structure which provides a unique mapping of in and outflows and therefore no different sign is needed."

Date of submission:
15/06/2015
Published as Final Q&A:
09/09/2016
Final Answer:

Validation rule v4421_s will be changed in a way that it requires maturing long term funding to be reported with a positive sign in row (200,230, 260,290,320) and column (020,030,040,050) in template P 01.02 of EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions. Also validation rule v4420_s will be amended to allow reporting of positive figures. Validation rules v4420_s and v4421_s will be deactivated until the changes are in place.

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