What exposure value should be used for Large Exposure purposes in situations where there is a difference between the accounting value used for IFRS accounting purposes and the value used for FinRep regulatory purposes?
The Large Exposure template instructions expand on Article 390 CRR and state that ‘The valuation of assets and off-balance-sheet items shall be effected in accordance with the accounting framework to which the institution is subject, according to Article 24 of CRR’.
On the other hand, Article 18(5) CRR, permits the equity method of accounting to be used for the consolidation of subsidiaries which have not otherwise been consolidated under Articles 18(1)-(4).
In a situation where the application of the equity method of accounting is required for regulatory purposes and where this differs from the method applied from an IFRS accounting perspective, it is unclear whether the equity method of accounting could be used for LE purposes, consistently with the determination under of Article 18(5).
Article 390 CRR does not address the actual value to be applied in all cases, e.g. the application of Article 18(5), equity method of accounting, in the valuation for Large exposures. This potential conflict appears to have been considered for FINREP (see Q&A 340, which might be helpful in addressing the issue, in the sense of explaining and confirming the change of value used under the accounting framework to the value used for FinRep.
The reporting instructions (Annex IX for Large Exposures) - specifically for the original exposure col 010 which say to use “the accounting framework to which the institution is subject” - appears to require accounting value to be the value recorded in the bank's own financial statements under IFRs
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