Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - Funding Plans
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EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
Disclose name of institution / entity:
Name of institution / submitter:
Bank of Spain
Country of incorporation / residence:
Type of submitter:
Competent authority
Subject Matter:
Clarification on Funding Plans significant currencies criteria

What rule should be followed given the discrepancy between what the EBA Guideline establishes and the criteria given by the template GL on FP?

Background on the question:

The part "4.4.4 Technical options proposed" from the "Guidelines on harmonized definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2 indicates that "A reporting credit institution only has to complete this if it has significant business (greater or equal to 5% of either assets or liabilities) in the foreign currency. However, in the instructions of Annex I Templates for GL on FP, in section 2c, Structural Currency Mismatches states "Please provide a breakdown of your balance sheet by the three largest material currencies. Please note, we only expect firms to report a currency where it accounts for more than 5% of total liabilities, as per CRR Art 415 2 b).

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

Template P 02.06 of Annex I of EBA/GL/2014/04 (the GL) refers to structural currency mismatches based on a breakdown of the three largest material currencies. The instructions currently refer to Art. 415 (2) lit. b CRR but they should refer to Art. 415 (2) lit. a CRR.

Institutions shall identify all material currencies, including reporting currency, based on the instructions provided in Annex I of the GL, i.e. based on the threshold for significant currencies in Article 415 (2) lit. a CRR which takes into account only the amount of liabilities, not of the assets.

If the institution identifies only one or two significant currencies, only those shall be reported.

Please see also Q&A 2015_2329 on reporting of reporting currency as material currency.

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