How shall row 190 (columns 015-070) within template 4.3.1 be filled in order to fully comply with, in our interpretation, contradictory attributes stated in the terms of both rows and columns?
Within the framework of the ITS on amendments to FINREP due to IFRS 9 (EBA-ITS-2016-07), templates 4.3.1 and 4.4.1 shall provide information on the share of financial assets already credit-impaired at purchase (rows 190/150). However, the general impairment model does not apply to purchased or originated credit impaired assets. Therefore, such classification as stage 4 credit-impaired assets is incompatible with the content of columns 015-070 which refer to the impairment stages 1-3. Therefore, it appears to us as if row 190 in 4.3.1, as well as row 150 in 4.4.1, cannot be filled in accordance to both criteria shown in the matrix of those two reporting template.
Purchased or originated financial assets that are credit-impaired at initial recognition as defined in IFRS 9 Appendix A shall be separately reported in templates 4.3.1 and 4.4.1. For these assets, the accumulated impairment shall only include the cumulative changes in lifetime expected credit losses since initial recognition [IFRS 184.108.40.206]. The corresponding gross carrying amount and accumulated impairment for these assets shall be reported in ‘Credit-impaired assets (Stage 3)’ at initial recognition and as long as they are considered as credit-impaired assets in accordance with the definition of ‘credit-impaired financial assets’ of IFRS 9 Appendix A. When they are not anymore considered as credit-impaired assets after initial recognition, they shall be reported in ‘Assets with significant increase in credit risk since initial recognition but not credit-impaired (Stage 2).
The ITS will be amended accordingly. In the meantime, the approach outlined above should be already used.