Is it correct that the formula in COREP Table C 05.01, r100,c040 does not take into account the new cell r440,c040 (Adjustments due to IFRS 9 transitional arrangements)?
As from March 2018, a new row (r440) has been added in Table 5.01 of the COREP template in order for the institutions to report separately the adjustments that concern the transitional arrangements of IFRS9. However cell r440,c040 is not taken into account neither in r140,c040 nor in r0100 & r010,c040. As a result the total figure reported in r010,c040 which represents the total adjustments on RWAs is not correct.
Validation rule v0269 should not be changed, as transitional arrangements for IFRS 9 is not a subcomponent of “deductions”.
However, it is true that, contrary to what is done for adjustments to CET1, AT1 and T2 via the validation rules v0255_m, v0256_m and v0264_m, the total of adjustments for RWAs does not take into account row 440: “adjustments due to IFRS9 transitional arrangements” via a validation rule.
To be consistent with validation of adjustments to CET1, AT1 and T2 a new validation rule shall be created for RWA (r440) using the following formula :
{C05.01; r100; c 040} = {C 05.01; r140; c040} + {C 05.01; r430; c040} + {C 05.01; r440; c 040}