Question ID
2017_3192
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 II, C 102.00, column 100
Type of submitter
Credit institution
Subject matter
Supervisory Benchmarking Exercise, Annex II, C 102.00, Column 100 - Facilities
Question

How should we classify exposures into the list of facility types provided in the templates?

Background on the question
  1. When classifying exposures into type of facility, how should non-lending exposures be categorised? E.g., Derivatives, SFT, Deposits etc would be “Not Applicable” type of facility? Or should the submission be restricted to only lending exposures?
  2. How should we report cases where we have multiple facilities to a single entity? Should we have a separate row for each facility type?
  3. How should partially-drawn facilities be reported, as the facilities types listed in the template only classifies a facility as “drawn” or “undrawn”. For example, if a $100m facility is 30% drawn, do we report it in both rows, with $30m EAD in the “drawn” row and $70m EAD in the “undrawn” row?
  4. Option (g) mentions “short-term letters of credit” – what is the threshold period for letters of credit to be considered short term? (e.g. 12-months and under?)
Submission date
Final answer

Question 1

Facilities which are neither off-balance sheet items as listed in Annex I to Regulation (EU) No 575/2013 (CRR) nor drawn credit facilities shall be assigned to the type of facility “full risk” listed in the instructions on column 100 of template C 102.00 of Annex I to the Draft ITS on Supervisory Reporting for Institutions for benchmarking the internal approaches (ITS on Supervisory Benchmarking; see also Q 2016_2902) as provided in Annex II of the ITS on Supervisory Benchmarking.

They shall also be included in those portfolios where no type of facility is specified (i.e. where c100 = ‘not applicable’).

Question 2

The information reported in template C 102.00 of Annex III of the ITS on Supervisory Benchmarking is an aggregated reporting (by portfolio, not by obligor). Based on the information provided in c100 of Annex I of the ITS on Supervisory Benchmarking, facilities are assigned to certain portfolios. Hence, multiple facilities to a single entity are reported in different portfolios, based on the type of those facilities.

See also Q&A 2016_3066

Question 3

See Q&A 2016_3066

Question 4

See Q&A 2017_3105

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. The text of the Implementing Regulation may differ from the text of the draft ITS to which this Q&A refers.

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.