Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Draft ITS on Supervisory Reporting of Institutions
Annex III - instructions for template prices for various lengths of funding
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Reporting requirement for draw down of facilities

In the case of revolving committed credit facilities, should the capacity of facility, upon renewal/commencement of the arrangement, or each individual draw of the facility be reported for the volume amount in template 69?

Background on the question:

The template aims to collect average transaction volume and prices paid for funding. If a firm arranges access to or renews a facility provided to it, then in the following example what should be reported? The facility in the example is committed. Month 1 - facility is renewed or arranged. Capacity of facility (volume) = y, Spread = x bps, Term = 2years (a hypothetical contractual term the facility is committed to the organisation). However no draw down of the facility is initiated. Month 2 - firm draws half of the available facility. Therefore volume = y/2, spread x bps, and the draw term = 1 month, however the draw can be unconditionally rolled over up until facility expiration (i.e. 2 years) Whether the firm draws y or y/2 the spread is unchanged. Therefore should the firm report the full amount of the facility (y), spread (x) and term 2 years for month 1, or report the draw on the facility (y/2), spread (x) on month 2? And if reporting month 2 position only, should the term equal the initial term (1 month) or a term reflecting the firm's ability to unconditionally roll the funding received i.e. 2 years?

Date of submission:
Published as Final Q&A:
Final Answer:

In C 69.00 of Annex XX of final draft implementing technical standard (ITS) on additional liquidity monitoring metrics under Article 415(3)(b) of Regulation (EU) No 575/2013 (EBA/ITS/2013/11/rev1 (of 24 July 2014)) institutions should only report on-balance sheet items. This means that the facility is not reported when the contract is signed. It is only with the first subsequent drawdown that it will be reported. The “carrying amount” to be reported should be the maximum amount drawn in the reporting period. The original maturity of the drawdown should be the original maturity of the facility provided that the amount drawn can be rolled-over at discretion of the reporting institutions. If the drawdown cannot be rolled-over at discretion of the institution, then the actual maturity of the drawdown should be considered. In the following reporting period, assuming the reporting institutions increases the usage of the facility, only the additional amount drawn should be reported.  



The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal, which may differ from the text of the draft ITS to which this Q&A relates.

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