Table F 18.00 of FINREP contains the breakdown by past-due time bands of performing and non-performing exposures. In case of "debtor approach" how should the exposures to a given debtor be allocated to columns? And do such criteria have to be applied to both performing and non-performing debtors?

Some columns of template F 18 represent exposures broken down by past-due time bands. In particular, columns 30, 40, 50 represent the breakdown of performing exposures; columns 70 to 100 represent the breakdown of non-performing exposures; finally, columns 160 to 190 represent the breakdown of the accumulated impairment. We have thought of two reasonable ways to allocate the exposures to a debtor assessed by "debtor approach": 1) one possible way could be to allocate the overall exposure in the same column according to the one with longer past-due time; 2) an alternative way could be to allocate each single exposure separately according to its past-due time. Example a): a non performing debtor has 190 days past-due mortgage and a 100 days past-due overdraft. According to the first criterion the overall amount of the two exposures would be allocated in the column 90 ("more than 180 days but not more than 1 year"). Following the second criterion the overdraft would be allocated in the column 80 ("more than 90 days but not more than 180 days") while the amount of mortgage would be allocated in the column 90 ("more than 180 days but not more than 1 year"). Example b): a non-performing debtor has a small mortgage with regular payments and a 190 days past-due large overdraft. According to the first criterion the overall amount of the two exposures would be allocated in the column 90 ("more than 180 but not more than 1 year"). Following the second criterion the amount of the mortgage would be allocated in the column 70 ("unlikely to pay that is not past-due or past-due <= 90 days") while the overdraft would be allocated in the column 90 ("more than 180 days but not more than 1 year").