Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - FINREP (incl. FB&NPE)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Annex III, IV, V
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Possible error in v8116_m

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.

Date of submission:
Published as Final Q&A:
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.

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