Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Annexes III and IV to Regulation (EU) No 680/2014
Disclose name of institution / entity:
Name of institution / submitter:
Triodos Bank NV
Country of incorporation / residence:
Type of submitter:
Credit institution
Subject Matter:
Inconsistencies in validation rules v1974_h, v5447_m, v5475_m and v5443_m

Whilst implementing DPM 2.7 we ran into some inconsistencies in the validation rules. The inconsistencies are caused by the validation rules as mentioned below. eba_v1974_h [F 17.01 (c010)] {r231} = +{r232} + {r233} Issue: in dpm 2.7 row 380 for equity instruments was added in report F17.00 and is part of row 231 but is not part of the right side of the equation. eba_v5447_m {F 18.00.a, r180, c010} = sum({F 04.09, r140, (c010, c020)}) + sum({F 04.10, r190, (c010, c020)}) - sum({F 04.10, r190, (c015, c025)}) + sum({F 01.01, (r030, r040), c010}) Issue: in report F18.00 row 180 only contains debt securities and loans and advances, whereas in the F4.x reports equity instruments are included as well (here, report F4.08 reports equity instruments). Rule eba_v5475_m has the same issue eba_v5443_m [F 18.00.a] {F 18.00.a, r100, c010} = sum({F 04.09, r100, (c010, c020)}) + sum({F 04.10, r150, (c010, c020)}) - sum({F 04.10, r150, (c015, c025)}) + {F 01.01, r030, c010} In template 18, the amount is for credit institutions, whereas the {F 01.01, r030, c010} refers to cash at central banks. If the reference was to row 40 (other demand deposits) instead of 30, the calculation would add up The question is: How to handle these inconsistencies?

Background on the question:

Inconsistencies in the DPM 2.7 validation rules The issues are outlined in the question itself.

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

It is correct that row 231 of template F 17.01 of Annex IV to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) includes equity instruments, which is correctly reflected in validation rule v5147_m. v1974_h has been deactivated on 10/09/2018.

Template F 18.00 of Annexes III and IV excludes equity instruments. v5447_m and v5475_m incorrectly include equity instruments on the right hand side of the equation and will have to be amended. Please see Q&A 2018_3814 for other issues with v5447_m.

With regard to v5443_m, please refer to Q&A 2018_3814.


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