Question ID:
2020_5277
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - COREP (incl. IP Losses)
Article:
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Article/Paragraph:
Annex XV
Disclose name of institution / entity:
No
Type of submitter:
Credit institution
Subject Matter:
Validation rules V_7329; V_7403 and V7409
Question:

Does validation rule V_7329; V_7403 and V7409 apply for columns that can (should) contain a negative amounts?

Background on the question:

Negative amounts make that these three validation rules do not hold.

v7329_m states according to the validation rules (last updated 10 March 2020): {r0010} >= ({r0450} + {r0460} + {r0470} + {r0480} + {r0500} + {r0510} + {r0520} + {r0530} + {r0540} + {r0550} + {r0560} + {r0570} + {r0580} + {r0590} + {r0600} + {r0610} + {r0620} + {r0630} + {r0640} + {r0650} + {r0660} + {r0670}).
This validation rule is also applicable for C0190. However this column should contain a negative amount, making that the validation rule does not work (inconsistent).

v7403_m states according to the validation rules (last updated 10 March 2020): {r0030} = {r0040} + {r0050}.
This validation rule is also applicable for C0020, C0030, C0060, C0080, C0090, C0100, C0130, C0190, C0900 and c0910. However these columns should contain a negative amount, making that the validation rule does not work (inconsistent).

v7409_m states according to the validation rules (last updated 10 March 2020): {r0170} >= {r0180}.
This validation rule is also applicable for C0020, C0030, C0060, C0080, C0090, C0100, C0130, C0190, C0900 and c0910. However these columns should contain a negative amount, making that the validation rule does not work (inconsistent).

Date of submission:
26/05/2020
Published as Final Q&A:
19/03/2021
EBA Answer:

While the inclusion of negative and positive sign rows may influence the result or sign of a comparison between values (such as in v7409_m), it does not affect the rules that merely state the result of a formula, already considering the signs of the components (such as v7403_m).
Therefore, v7409_m (and v7329_m) were wrong and have been corrected so that they can apply to columns that may contain negative values, while v7403_m is right as it can be applied already to columns that may contain negative values.

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