According to the amended validation rule column 060, row 010 of template C 05.01 should be reported as greater or equal to zero.

On the other hand, the ITS sign convention states any amount that increases the own funds or the capital requirements shall be reported as a positive figure while any amount that reduces the total own funds or the capital requirements shall be reported as a negative figure.

In our example given in ‘Background on the question’ box, row 010, column 060 (Total adjustments) represents net deductions and therefore is to be reported as negative. In fact in EBA Q&A 2015_2482 it states that those rows of column 060 which show deductions according to final provisions are reported with a negative sign.

Our concern is that a bank is reporting a negative figure in this cell due to the fact that under item unrealised gains it is reporting €50 billion (r120 c060) while under deferred tax assets that rely on future profitability (r170 c060) the bank reports (-)€90 billion. There are no other items in column 060. Does this lead to a negative €40 billion figure in row 010 column 060? In this case is the validation check v3693_s still valid for row 010 column 060?

The amended validation rule v3693_s expects {r010, c060} of template C 05.01 of Annex I to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) to be reported as a positive value. This is incorrect, as this cell represents a sum of capital items and instruments (reported with a positive sign in accordance with the COREP sign convention), deductions (reported with a negative sign) and other elements, which can turn both positive and negative.

The scope of application of v3693_s will be adjusted to exclude {C 05.01, r010, c060}.