Question ID
2022_6542
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Article/Paragraph
Annex III, IV, V
Type of submitter
Credit institution
Subject matter
Possible error in v8116_m
Question

Is the following rule v8116_m: [F18.01 (c0020)] {r0050} <= {r0060} correct?

Background on the question

We have a situation now that a client was a Small and Medium-sized Enterprise (SME) at the opening balance but no SME anymore at the closing balance.

As a consequence, we have to report in FINREP template F 18.01, cell r0060-c0020, the amount as an outflow.

However, on the line above, cell r0050-c0020 is not impacted because the loan is still active and the impairment as well.

So, the amount in cell r0060-c0020 can be smaller (more negative) than the amount in cell r0050-c0020.

Submission date
Final publishing date
Final answer

The change in a portfolio due to a reclassification of a counterparty shall not be considered as an outflow from non-performing exposures as derived from Part 2, paragraph 239v of the ITS 2021/451.

If an outflow from a non-performing exposure is reported in row 0060 “Of which: Small and Medium-sized Enterprises” it shall also be reported in row 0050 “Non-financial corporations”. In case the counterparty is not anymore classified as small and medium-sized enterprise at the reporting date, any outflow from non-performing exposures to this counterparty that was occurred during the reporting period will be reported only in row 0050 as indicated in Part 2, paragraph 239iv of the ITS 2021/451.

Therefore, the validation rule v8116_m is applicable.

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

Disclaimer

The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.