Question ID:
2017_3591
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Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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, template F 18.00.a/F 04.04.1/F 01.01
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
IFRS 9, validation rule v2776_m
Question:

Validation v2776_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. 

Background on the question:

v2776_m = {F 18.00.a, r100, c010} = sum({F 04.04.1, r100, (c015, c030, c040)}) + {F 01.01, r040, c010}

Validation rule v2776_m (taxonomy 2.7) for IFRS 9 compares the gross carrying amount for Loans and Advances for credit institutions of template F 18.00 with the gross carrying amount for Loans and Advances for credit institutions of template F 04.04.1 plus the carrying amount for Other demand deposits of template F 01.01. However, template F 01.01 includes only the carrying amount. Therefore, this validation seems to be incorrect as table 1.1. is NOT the gross carrying amount.

Date of submission:
09/11/2017
Published as Final Q&A:
11/01/2019
Final Answer:

According to Part 2, paragraph 217 of Annex V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), template F 18.00 of Annexes III and IV to the ITS on Supervisory Reporting covers also cash balances at central banks and other demand deposits. The validation rules confirms this scope of exposures. Template F 01.01 of Annexes III and IV does include only the carrying amount of cash balances and other demand deposits; in case there would be impairments booked against these items, validation rule v2776_m may not hold.

This also applies for validation rules v2773_m, v2774_m and v2780_m. 

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