Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
99, 100
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Annexes III, IV and XVI, validation rules
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Validation rules v2817_m & v2823_m between the Finrep conso & AE-CON conso reportings

We have 2 validation rules v2817_m & v2823_m that can't be solved between the Finrep conso & AE-CON conso reportings.

  1. For the Debt securities sum({F 32.01, r040, (c010, c060)}) = sum({F 01.01, c010, (r080, r094, r120, r160, r173, r177, r190, r220, r232, r236)}) [v2817_m] checks the total of debt securities in the Finrep with total of debt securities reported in AE F32.01

  There are additional checks on details;

  • For Central govs:
    if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r070, (c010, c060)}) = {F 04.01, r080,c010} + {F 04.02, r080,c010} + {F 04.03, r080,c030} + sum({F 04.04, c060, (r030, r170)}) [v2818_m]
  • For Financial corporations:
    if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r080, (c010, c060)}) = sum({F 04.01, c010, (r090-100)}) + sum({F 04.02, c010, (r090-100)}) + sum({F 04.03, c030, (r090-100)}) + sum({F 04.04, c060, (r040-050, r180-190)}) [v2819_m]
  • For corporations:
    if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r090, (c010, c060)}) = {F 04.01, r110,c010} + {F 04.02, r110,c010} + {F 04.03, r110,c030} + sum({F 04.04, c060, (r060, r200)}) [v2820_m]

In the Finrep report the covered bonds & asset backed securities are reported in 1 of the 3 above categories while in the Asset encumbrance tables these types of securities are part of a separate category. Those rules doesn't allow Banks to report anything in the AE for covered bonds and asset backed securities …

  1. Other assets sum({F 32.01, r120, (c010, c060)}) = sum({F 01.01, c010, (r020, r060, r092, r240-260, r290, r320-330, r360-370)}) [v2823_m] doesn't contain PPE and goodwill. Then total of assets in asset encumbrance can't be reconciled with total asset in the Finrep.

  We considered the following check as a control that both amounts are more or less aligned: {F 36.01.c, r230,c180} ≡ {F 01.01, r380,c010}

Background on the question:

Based on comments mentioned above, those validations rules between Finrep & AE reportes should be revised

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

Validation rule v2817_m is correct.

Rows 050 and 060 and 070 to 090 of template F 32.01 of Annexes III and IV to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) are not complementary. Securities included in lines 050 and 060 shall be also included in lines 070, 080 or 090 according to their counterparty.

For validation rule v2823_m, please see Q&A 2014_1671.

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