- Question ID
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2014_878
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Supervisory reporting - FINREP (incl. FB&NPE)
- Article
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99
- Paragraph
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2
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Draft ITS on Supervisory Reporting of Institutions
- Article/Paragraph
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F19.00
- Type of submitter
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Consultancy firm
- Subject matter
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Scope for probation period
- Question
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Paragraph 176 defines the criteria to discontinue forbearance classification. According to paragraph 176 (b) "...a minimum 2 year probation period has passed from the date the forborne exposure was considered as performing". According to Annex II “EBA ITS 2013 03 Annex I (Annex I ITS FBE NPE Amemdments Annex III ITS reporting IFRS templates)” paragraph 176 (b) is only applicable to table 19 column 50 (of which: Performing forborne exposures under probation). Does this mean that the 2 year probation period is only required for exposures which are reported in column 50 – i.e. exposures with forbearance measures which have been reclassified out of the non-performing forborne exposure columns (see paragraph 180)?
- Background on the question
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At the moment it is not clear whether the 2 year probation period is applicable only to forborne exposures that have been reclassified from the non-performing category or generally to all performing exposure with forbearance measures.
- Submission date
- Final publishing date
-
- Final answer
-
The two years’ probation period is applicable to all forborne exposures, irrespective of whether they were classified as performing or non-performing when the forbearance measures were granted:a) The probation period applicable to a performing exposure that was not classified as non-performing at the date the forbearance measure was extended or for which the forbearance measures have not led the exposure to be classified as non-performing begins at the date the forbearance measure was granted (paragraph 177);b) The probation period of a non-performing forborne exposure begins the day the exposure is qualified as performing (paragraph 176).The rules for non-performing forborne exposures in b) above are applied to performing forborne exposures reclassified out of the non-performing category (paragraph 176) and to forborne exposures reclassified as non-performing in application of paragraph 179, as the application of paragraph 179 interrupts the probation period of a performing forborne exposure (the scope of application of paragraph 179 is further specified in Q&A 2014_736). Although the probation period applies to all forborne exposures, according to paragraph 180 of Annex V of Regulation (EU) No 680/2014 – ITS on Supervisory Reporting of institutions (ITS), only those performing forborne exposures reclassified from the non-performing category and which are in the probation period (exposures under point b) above) shall be reported in column 050 of F 19.00. The content of column 050 of F 19.00 is further specified in Q&A 2014_736.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.
Disclaimer
The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.