Question ID:
2021_6282
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Asset Encumbrance
Article:
430
Paragraph:
1
Subparagraph:
g
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Article/Paragraph:
Annex XVII, 1.2
Disclose name of institution / entity:
No
Type of submitter:
Competent authority
Subject Matter:
Reporting collateral received for derivatives in AE templates F 32.04 (AE-SOU) and F 32.02 (AE-COL) when master netting agreements are in place
Question:

Can the collateral received for derivatives be reported in AE templates F 32.04 (AE-SOU) and F 32.02 (AE-COL) at master netting agreement level (counterparty level), when collateral is only exchanged at that level?

Background on the question:

The instructions in Annex 17 of Regulation (EU) 2021/451 specify that in AE-SOU institutions shall generally report carrying amounts gross of accounting netting, if any, in line with the reporting on a gross basis of encumbrance of assets and collateral.

When master netting agreements are in place (usually a Credit Support Annex -‘CSA’- of a ISDA Master Agreement), margin calls for derivative portfolios traded under CSAs are made and exchanged based on the net mark-to-market exposure of derivatives in that portfolio, rather than exchange margin on each trade individually, therefore there will be a single margin call and margin exchange between the two parties for trades under a given CSA on a given day. In this case, institutions typically report in {F 32.04, r0020-0030, c0030} the collateral received at CSA-level. Given that the collateral is posted and received at CSA-level, a more ‘gross’ reporting of collateral (i.e. at trade level), is usually not possible. To ensure consistency between the AE templates and to comply with the validation rule specified in Annex 17 (The total amounts of assets and collateral received in the AE-ASS and the AE-COL templates meet the following validation rule: {AE-SOU; r170; c030} = {AE-ASS; r010; c010} + {AE-COL; r130; c010} + {AE-COL; r240; c010}), the collateral received related to derivatives is reported in F 32.02 (AE_COL) also at CSA level.

However, the carrying amount of the liabilities related to these derivatives is reported in {F 32.04, r0020-0030, c0010} as per applicable accounting rules (i.e. gross at a trade-level) even where a master netting agreement exists, therefore the values in columns 0010 and 0030 are not comparable.

Date of submission:
17/11/2021
Status:
Question under review
Answer prepared by:
Answer prepared by the EBA.
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