2018_4428 EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)

Question ID:: 2018_4428
Legal Act:: Directive 2013/36/EU (CRD)
Topic:: Supervisory reporting - Supervisory Benchmarking
Article:: 78
Paragraph:: 2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
Article/Paragraph:: Annex 5, section 2, Instrument No. 40
Disclose name of institution / entity:: No
Type of submitter:: Competent authority
Subject Matter:: EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)
Question:: What is the correct interpretation of instrument No.40?
Background on the question:: The description of instrument 40 is ambiguous. The booking of a normal FX Spot trade with a standard delivery date of T+2 (== 21.09.2018) – a possible interpretation of the ITS instructions – results in an IMV value of zero as the trade has already matured on the IMV date.
Date of submission:: 20/12/2018
Published as Final Q&A:: 26/07/2019
Final Answer:: With regard to Instruments 40, section 2, Annex 5 of the Regulation (EU) 2016/2070 - ITS on Supervisory Reporting, ~~for the exercise 2019,~~ the instruments has to be considered as 1 million USD cash (long position, to be reported in Euro). The long cash position of USD 1 million should be booked on the booking date. The cash position should continue to exist throughout the exercise and not mature prematurely (whereas an FX spot purchase would mature at delivery). For IMV purposes, institutions should report the market value of the long cash position of USD 1 million in the base currency of the instrument, i.e. EUR.
Status:: Final Q&A
Answer prepared by:: Answer prepared by the EBA.
Note to Q&A:: Update 03.12.2021: This Q&A has been updated in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking.