Question ID:
2021_6038
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
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:
DPM 3.0 - C80.00 ; C84.00.
Disclose name of institution / entity:
No
Type of submitter:
Other
Subject Matter:
DPM 3.0 - C80.00 - C84.00 - Inconsistent modelisation and validation rules v10127_m and v10143_m.
Question:

Modelisation issue between report C80.00 and C84.00 but only for the sheets giving a breakdown per currency as we have some inconsistent duplicated fact.

See background on the question.

Background on the question:

This issues is blocking for many fillers and should processed urgently.

Indeed it seems that with the current XBRL modelisation, cell C8400w r0100 c0200 should be equal to cell C8400w r1020 c0130 for a given currency.

This modelisation is not aligned with the modelisation done on the TOTAL sheet which states that cell C8400 r0100 c0200 should be equal to cell C8000 r0970 c0130

When we look at the ITS we see that the following equality are indicated :

C8400

0100

1.9 RSF from other assets

Item 1.9 of reporting templates C 80.00 and C 82.00

C8000

0970

1.9 RSF from other assets

Institutions shall report here any asset not referred to in items 1.1 to 1.8.

When we look at the DPM we see that the modelisaiton issue seems to be linked to the value of the DIMENSION MC which differs on report C8400 between the TOTAL sheet and the sheet giving the breakdown per currency.

C8400 - TOTAL SHEET

RSF from other assets

0100

455484

€£$

458806

€£$

€£$

%

(BA:x27) Required stable funding

(MC:x1069) Physically traded commodities, trade date receivables, non-performing assets and other assets

C8400 - BREAKDOWN PER CURRENCY SHEET

RSF from other assets

0100

455210

€£$

458670

€£$

€£$

%

(BA:x27) Required stable funding

(MC:x1052) Other RSF assets

From our point of view the dimension MC should have the value (MC:x1069) Physically traded commodities, trade date receivables, non-performing assets and other assets on the row 0100 of report C8400 – breakdown per currency

Furthermore, the taxonomy states :

a)From a modellisation point of view it seems that the cell C8400w r0010 C0020 == C08000w r0010 c0130.

       

b)That the amount to be reported in column 0020 of report C8400 should be equal to the sum of the sub ITEM of C8400

v10158_m

 

3.0.0

Add

       

Manual

 

Warning

C 84.00.w

             

(0010;0020)

(All)

{C 84.00.w, r0010} = {C 84.00.w, r0020} + {C 84.00.w, r0030} + {C 84.00.w, r0040} + {C 84.00.w, r0050} + {C 84.00.w, r0060} + {C 84.00.w, r0070} + {C 84.00.w, r0090} + {C 84.00.w, r0100} + {C 84.00.w, r0110}

c) That the amount to be reported in column 0130 row 0010 is calculated via a sum of various sub items, of which the row r0970 which is calculated as a sum of various sub items of which the row r1020

v10117_m

 

3.0.0

Add

       

Manual

 

Warning

C 80.00.w

   

(0010;0020;0030;0040;0130)

(All)

{r0010} = {r0020} + {r0080} + {r0560} + {r0620} + {r0850} + {r0910} + {r0960} + {r0970} + {r1040}

C 80.00.w

treat as zero/empty string

Interval

v10127_m

 

3.0.0

Add

       

Manual

 

Warning

C 80.00.w

   

(0010;0020;0030;0040;0130)

(All)

{r0970} = {r0980} + {r1010} + {r1020} + {r1030}

  • Considering the point a,b and c we do not see a way for our client to report a valid XBRL instance that will satisfy all the validation rules.
    • Indeed in order to pass the modelisation constraint we should report :
      • A false amount in C8400w r0100 c0020 equal to the amount in C8000w r1020 C0130
      • A correct amount in C8400w r0010 c0020 equal to the amount in C8000w r0010 C0130, which won’t satisfy the validation rule v10158_m

Please can you tell us if you will publish a corrective version of the report C8400, or if we need to tell our client to declare some false amount in C8400 R0100 C0020 and to not take into consideration the validation rule v10158_m

Date of submission:
15/06/2021
Published as Final Q&A:
23/07/2021
EBA Answer:

In table C 84.00w of the data point model to Regulation (EU) No 680/2014 (ITS on supervisory reporting), Main category has been modelled inconsistently with other templates for R0100 (RSF from other assets) and R0210 (ASF from other assets). In addition, few other modelling issues have been identified: it is acknowledged that C8000w r1020 is wrongly missing the dimension (IMS:IM). On the other hand,C 80.00w r 1030 is wrongly including (IM:x16) Non-performing exposures. It is acknowledged that in C 84 r0150, r0130, operational deposits should be excluded as they are to be reported in a separate row R0160.

The modelling issues identified have led to incorrect identities across templates, namely:

1. C81.00a r0230 c0100 = C84.00a r0180 c0030

2. C81.00w r0230 c0100 = C84.00w r0180 c0030

3. C81.00.a-r0130-c0100 = C84.00.a-r0150-c0030

4. C81.00.w-r0130-c0100 = C84.00.w-r0150-c0030

5. C81.00w r0430 c0100 = C84.00w r0210 c0030 6. C80.00.w-r1020-c0130 = C84.00.w-r0100-c0020

While the modelling will be corrected at the next available opportunity, as an interim solution, the values in the summary template (C 84.00) should be the ones correctly reported. The associated validation rules will be deactivated.

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