Question ID
2021_6094
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Leverage ratio
Article
430
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Article/Paragraph
Annex XI
Name of institution / submitter
Wolters Kluwer
Country of incorporation / residence
Netherlands
Type of submitter
Other
Subject matter
Cash pool assets in C 47.00
Question

As per ITS of C47, Cash pool assets are to be reported in C47 Rows 0193 to 0198.

[1] As net amount of cash pool asset for the group entity are likely to reported in Row 0190, of C47 as other assets. Is it not double counted to the extent of amount reported in Row0190 with regard cash pool assets?

[2] As there is validation (v4456) between C47 Rows 0010 to 0290 = C43 total assets, where are these cash pool assets as reported in C47 are to be reported in C43?

[3] Whether Cash pool assets as reported in C47 are also to be reported including positive and negative amounts.

[4] Is the scope of prudential netting mentioned under article 429b, applicable only for Leverage ratio or does this prudential netting has some thing to do with prudential report applications like COREP?   

Background on the question

There are guidelines of cash pool assets to be reported in C47. 

But, cash pool assets, the net amount if it is an asset it will also likely to be reported in Row 0190. It leads to duplicate amounts.

There is no guidance in ITS regarding reporting of cash pool assets in C43 and C40. Mainly there is validation rule between C43 and C47

Submission date
Final publishing date
Final answer

In accordance with the instructions for template C 47.00 of Annex XI to Regulation (EU) 2021/451, cash pooling arrangements are to be reported in rows {r0193} to {r0198} of template C 47.00.   

[1] According to the instructions for row {r0190} cash pooling arrangements shall not be considered in {r0190}. Hence, there is no double counting of exposure values related to cash pooling arrangements in C 47.00. 

[2] Assets subject to cash pooling arrangements in accordance with Article 429b(2) and (3) of Regulation (EU) No 575/2013 (CRR) shall be reported in the respective exposure class in C 43.00, corresponding to the institution’s categorization of the involved clients. 

[3] The reporting of cash pooling arrangements follows the instructions provided in Annex XI of the Implementing Technical Regulation (EU) 2021/451. In line with the provided instructions, reporting in rows {r0193} to {r0196} of C 47.00 is expected to be positive, whereas the effect of prudential netting in rows {r0197} and {r0198} is expected to be reported with a negative sign.  

[4] Article 429b CRR is included in Part Seven of the CRR related to the Leverage Ratio. Hence, provisions related to netting in cash pooling arrangements referred to in article 429b CRR exclusively relates to provisions in relation to the Leverage Ratio.  

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

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