Question ID:
2017_3098
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - FINREP (incl. FB&NPE)
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph:
Annex V, Part 1.24, 27, 42, 43 / Part 2.145-162 / Part 1.35(e)
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
FinRep validation rules v3079_m and v3080_m
Question:

According to the validation rules v3079_m and v3080_m, the loans and receivables for Non-financial corporations of template F 06.00 have to be equal with the loans and receivables for Non-financial corporations of template F 18.00. It is explicitly stated that only DEBT INSTRUMENTS AT FAIR VALUE OTHER THAN HFT have to be reported in table F 18.00. However table F 06.00 includes all debt instruments including HFT. Therefore the validation rule cannot be run with the defined operator "=".

Background on the question:

According to the validation rule 'v3080_m' the loans and receivables for Non-financial corporations (non-performing) of table F 06.00 have to be equal with the loans and receivables for Non-financial corporations of table F 18.00.a. It is explicitly stated that only DEBT INSTRUMENTS AT FAIR VALUE OTHER THAN HFT have to be reported in table F 18.00.a. However table F 06.00 includes all debt instruments including HFT. This discrepancy is similar to the validation rule v3079_m.

Date of submission:
13/01/2017
Published as Final Q&A:
07/04/2017
Final Answer:

The validation rule v3079_m was deactivated as the scope of column 010 of template F 06.00 of Annexes III and IV to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) is wider, i.e. in contrast to c010 of template F 18.00 of Annexes III and IV, it includes also loans and advances held for trading.

The validation rule v3080_m compares the stock of non-performing loans and advances, which are defined with reference to Part 2, paragraphs 145 – 162 of Annex V both for the purposes of template F 06.00 and F 18.00. Hence the definition and scope is the same between the templates and the rule remains valid.

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