Question ID
2015_2386
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
Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
Article/Paragraph
Annex I and Annex II
Name of institution / submitter
KBC BANK
Country of incorporation / residence
Belgium
Type of submitter
Credit institution
Subject matter
Annex I template 103 collateral types mortgages non-SME
Question

Annex I contains in the 103 template portfolio IDs of mortgages (non-SME) with as collateral type (column 120) either "Real estate collateral, other funded CRM and/or personal guarantees" and "Real estate collateral and other unfunded CRM". Neither collateral type is defined in Annex II, where only references are given to the c150-c210 of table 8.1 of ITS reporting (which do not conatin this mortgage specific collateral types). Please provide a definition of "Real estate collateral, other funded CRM and/or personal guarantees" and "Real estate collateral and other unfunded CRM". In particular we are unsure how to treat personal guarantees as we consider them to be unfunded CRM and thus seem to be in scope of both definitions, which does not appear logical.

Background on the question

Missing definition of "Real estate collateral, other funded CRM and/or personal guarantees" and "Real estate collateral and other unfunded CRM".

Submission date
Final answer
The Collateral types defined in template C 103.00 of Annex II of Draft ITS on Supervisory Reporting for Institutions for benchmarking the internal approaches (ITS on benchmarking) have been revised and aligned between the Annexes I and II in the ITS on benchmarking published on 12 May 2016 on the EBA website. DISCLAIMER: The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal, which may differ from the text of the draft ITS to which this Q&A relates.
Status
Archive
Answer prepared by
Answer prepared by the EBA.
Note to Q&A

Update 26.03.2021: This Q&A has been archived in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking.