F12.1a – Movements in allowance and provisions for credit losses

The EBA has introduced a new section for ‘Allowances for purchased or originated credit-impaired financial assets’ (row references r600-r750) with granular sub-sections for ‘Debt Securities’ and ‘Loans and Advances’, broken down by industry classification.

This new section has the existing column for ‘Increases due to origination and acquisition’ (column reference c020) greyed out:

This greying out of column c020 means that no data can go into the column for the Purchased / Originated Credit Impaired Assets. We believe this is an error in the design of the template as a bank, if we were to procure credit impaired financial assets from an outside third party or to write credit impaired facilities to potential new / existing customers, we would expect to report these balances against column c020 ‘Increases due to origination and acquisition’.

Can you please share your thoughts in terms of the rationale behind blocking c020 for the POCI rows r600-r750 and advise how we should proceed in the event we have to report these balances in future submissions?

As a bank, we are due to go live with FinRep 3.0 and we noticed the template design fault which may cause a problem in future submissions.

The general impairment model does not apply to purchased or originated credit impaired assets as defined in IFRS 9 Appendix A given that at initial recognition the credit risk is directly reflected in the effective interest rate [IFRS 9.5.4.1].
Indeed, in accordance with IFRS 9 for POCI, only the cumulative changes in lifetime expected credit losses since initial recognition shall be recognised as a loss allowance [IFRS 9.5.5.13].
Therefore, the greying out of column c020 in correspondence with the row r600 is correct.