- Question ID
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2016_2824
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Supervisory reporting - Asset Encumbrance
- Article
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100
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
- Article/Paragraph
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Annex XVI
- Name of institution / submitter
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Bank of Italy
- Country of incorporation / residence
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Italy
- Type of submitter
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Credit institution
- Subject matter
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Asset encumbrance templates - Some cells are mapped with the same data point of other ones, but not all of them can be reported on a consolidated basis
- Question
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Should be reported on a consolidated basis the cells related to F 36.01 and F 36.02 templates mapped with the same data point of the ones related to F 32.01 and F 32.02 templates, which have the coordinates specified below? In general, should columns 50 and 70 of templates F 36.01 and F 36.02 be reported on a consolidated basis?
- Background on the question
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Some validation rules involve cells that, if they were reported, could violate checks fixed. For example:
v2955_m (related to col 070; {r230} = {r190} + {r210}).
This quality check considers the cells “F_36.01, row 190, col 70” and “F_36.01, row 210, col 70” that were mapped with the same data point of the “F 32.01, r060, c 020” and “F 32.01, r060, c 070” ones for which it is not allowed collecting any data on a consolidated basis, according to EU Regulation 79/2015. If an entity reports any data for row 230 but nothing for 190 and 210 rows, this check will be violated.
v2953_m; (related to col 070; {r200} <= {r190}).
This quality check considers the cell “F_36.01, row 190, col 70” that was mapped with the same data point of “F 32.01, r060, c 020" one for which it is not allowed collecting any data on a consolidated basis, according to EU Regulation 2015/79
v2909_m (related to col 070; {F 36.01.c, r190} = sum({F 36.01.a, (r010, r030, r050, r070, r090, r110, r130, r150, r170)})).
This quality check considers the cell “F_36.01, row 190, col 70” that was mapped with the same data point of “F 32.01, r060, c 020"" one for which it is not allowed collecting any data on a consolidated basis, according to EU Regulation 2015/79
v2808_m (related to col 20; {r060} <= {r040})
If an entity reports data for the template coordinates "F_36.01, row 190, col 70", this validation rules will be violated. Actually it should be necessary to report data for the cell "F_32.01, r060, c 020" to fit this validation rule, although it is not allowed to do this according the EU Reg. 2015/79
v2829_m (related to col 20; {r180} <= {r160})
If an entity reports data for the template coordinates "F_36.02, row 190, col 70" this validation rules will be violated. Actually it should be necessary to report data for the cell "F_32.02, r180, c 020" to fit this validation rule, although it is not allowed to do this according the EU Reg. 2015/79.
Moreover, we kindly ask you further clarifications for the following issues, strictly connected to what we mentioned above.
- "F_36.01, row 190, col 50" “Total encumbered assets - Debt Securities - of which: covered bonds - of which: issued by other entities of the group” This cell was mapped with the same data point of "F 32.01, r050, c 020" Should be prohibited collecting data related to "F_36.01, row 190, col 50" on a consolidated basis?
- "F_36.01, row 190, col 70" “Total encumbered assets - Debt Securities - of which: asset-backed securities - of which: issued by other entities of the group” This cell was mapped with the same data point of "F 32.01, r060, c 020". Should be prohibited collecting data related to ""F_36.01, row 190, col 70"" on a consolidated basis?
- "F_36.01 row 210, col 50" “Total non-encumbered Assets - Debt Securities - of which: covered bonds - of which: issued by other entities of the group” This cell was mapped with the same data point of "F 32.01, r050, c 070". Should be prohibited collecting data related to ""F_36.01 row 210, col 50"" on a consolidated basis?
- "F_36.01 row 210, col 70" “Total non -encumbered collateral received - Debt Securities - of which: asset-backed securities - of which: issued by other entities of the group” This cell was mapped with the same data point of "F 32.01, r060, c 070". Should be prohibited collecting data related to ""F_36.01 row 210, col 70"" on a consolidated basis?
- "F_36.02 row 190, col 50" “Total encumbered collateral received - Debt Securities - of which: covered bonds - of which: issued by other entities of the group” This cell was mapped with the same data point of "F 32.02, r170, c 020". Should be prohibited collecting data related to "F_36.02 row 190, col 50" on a consolidated basis?
- "F_36.02, row 190, col 70" “Total encumbered collateral received - Debt Securities - of which: asset-backed securities - of which: issued by other entities of the group” This cell was mapped with the same data point of "F 32.02, r180, c 020". Should be prohibited collecting data related to "F_36.02 row 190, col 50" on a consolidated basis?
- Submission date
- Final publishing date
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- Final answer
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As indicated by the shading, columns 020 and 070 of template F 32.01, columns 020 and 050 of template F 32.02 and column 020 of template F 32.04 of Annex XVI to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) shall not be reported on consolidated level.
With regard to columns 050 and 070 of templates F 36.01 and F 36.02 of Annex XVI, those shall not be reported on consolidated level either, although explicit provisions on this are missing in the ITS on Supervisory Reporting. Annex XVI of the ITS on Supervisory Reporting will be updated to clarify this. In the meantime, institutions can already leave blank columns 050 and 070 of templates F 36.01 and F 36.02 of Annex XVI in reports on consolidated level.
Validation rules v2955_m, v2953_m, v2909_m, v2808_m and v2829_m are working correctly on a consolidated basis if no data is reported in columns 050 and 070 of templates F 36.01 and F 36.02 in accordance with this Q&A and will therefore not be deactivated.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.
Disclaimer
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