Question ID
2015_2329
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Funding Plans
Article
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
Article/Paragraph
P 02.06
Type of submitter
Competent authority
Subject matter
The 3 largest material currencies in the structural currency mismatches tables (P 02.06) of funding plan report
Question

According to the instructions for P 02.06, the table provides a breakdown of the 3 largest material currencies. The currency is material if it accounts for more than 5% of total liabilities, as per Art 415 (2) lit. b CRR. (We think the correct reference here is Art 415 (2) lit. a CRR.)

According to Art. 415 (2) lit. a) CRR,: an institution shall report separately to the competent authorities of the home Member State the items referred to in paragraph 1 in the currency below when it has:
(a) aggregate liabilities in a currency different from the reporting currency under paragraph 1 amounting to or exceeding 5 % of the institution's or the single liquidity subgroup's total liabilities

Does that mean that the reporting currency has to be reported?

If yes, how shall the reporting currency – take the Hungarian forint as example - be reported in the structural currency mismatches tables of funding plan report?

Background on the question

Due to the fact that the reporting currency is excluded from art. 415(2a) the above guidance is not clear that the reporting currency (Hungarian forint) belongs to the 3 largest currencies or not.

Submission date
Final publishing date
Final answer

Template P 02.06 of EBA/GL/2014/04 (Guideline on Funding Plans) refers to structural currency mismatches based on a breakdown of the three largest material currencies. In the instructions for template P 02.06 it is stated that one should “… provide a breakdown of your balance sheet by 3 largest material currencies.  Please note, we only expect firms to report a currency where it accounts for more than 5% of total liabilities, as per CRR Art 415 2 (b).” The instructions currently refer to Art. 415 2 lit. b CRR, but they should refer to Art. 415 (2) lit. a CRR.

Institutions shall identify all material currencies, including reporting currency, based on the threshold above.

The reporting currency – in this Q&A the case refers to Hungarian forint – should be reported in template P 02.06. That is, for an institution with Hungarian forint as the reporting currency and with 3 largest significant currencies in EUR, USD and GBP in accordance with Art. 415 (2) lit. a CRR, the institution is expected to report data in HUF, and two largest foreign currencies when they are significant as per Art 415 (2) lit. a CRR in P 02.06. This corresponds to the point a) in the proposed answer. Please note that, as template P 02.06 is a replicating table, this should be reported three times in the current example with data on each major currency denominated in the reporting currency.

Please see also Q&A 2015_2388 on application of threshold.

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

Disclaimer

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