What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

For v2.8 framework version, a new validation rule was added, v6167_m, C 101.00:  {c050} <= 31-Dec-'current year-1'. Please help me with some clarification regarding the current year interpretation in this formula.

From a technical perspective it is a little bit confusing as end of year might be considered reference date of report and this might have a totally different meaning than the current year.

Commission Implementing Regulation (EU) 2016/2070 specifies the instructions for the reporting of supervisory benchmarking of internal approaches for calculating own funds requirements, according to article 78(2) of Directive 2013/36/EU. In particular, according to the instructions referred to in Table C 101 of Annex IV, column 050 (“Date of most recent rating of counterparty”) shall contain the date of the most recent rating of the counterparty.

Validation rule v6167_m further specifies that the most recent rating date shall be reported, as long as it falls within the time frame of the benchmarking exercise. For example, let us consider a counterparty that has received a rating on February 2017, October 2017 and February 2018. For the benchmarking exercise of December 2017 the rating that occurred in October 2017 shall be considered, even if there exists a later rating taking place before the actual reporting date.