Question ID:
2021_5736
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 II, part 3.7.1 paragraph 100
Disclose name of institution / entity:
No
Type of submitter:
Other
Subject Matter:
Validation rule v7378 - securitization templates C 13.01 and C 14.01
Question:

Should validation rule v7378 be triggered in case you have 1 entity which leads to a significant risk transfer (SRT) and 1 entity that is not leading to a SRT?

Background on the question:

We report 2 entities in template C 14.01 however only 1 in template C 13.01. We refer to the general remarks paragraph 100 of Annex II from the ITS stating
"100.In case the institution acts as originator, the information in this template shall be required for all securitisations for which a significant risk transfer is recognised. In case the institution acts as investor, all exposures shall be reported."

The validation rule is implemented to check whether the total exposure in C 14.01 column 0411 matches with C 13.01 row 010 column 180. This will not match in case you report 2 entities in C 14.01 (1 entity with significant risk transfer (SRT) and 1 entity without SRT) and compare it to the exposure of the single entity with SRT.
Moreover, validation rule v7378 seems inconsistent because the two templates do not cover the same scope. Indeed, according to the Annex II of the ITS on Supervisory Reporting the CR SEC template gathers information on securitization held in the banking book, while the SEC Details 2 held gathers information held in both the banking book and the trading book.

Date of submission:
12/02/2021
Published as Final Q&A:
10/09/2021
EBA Answer:

EBA validation rule v7378_m states that the sum of the exposure values reported in column 411 of template C 14.01 on a transaction basis on all securitisation positions held by the institution shall be equal to the total exposure value of securitisation positions calculated in accordance with Article 248 CRR reported in column 180 of template C 13.01. According to section 3.7.1 institutions shall only report data in template C 13.01 on securitisations that are held in the banking book. Since, according to section 3.8.2, reporting in column 0411 of C 14.01 is not applicable to securitization positions in the trading book, validation rule v7378_m is correct.

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