Question ID
2022_6550
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Leverage ratio
Article
429a (1)
Paragraph
(d)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
429a (1) (d)
Type of submitter
Other
Subject matter
Promotional loans that constitute claims on central governments, regional governments, local authorities or public sector entities
Question

As per article 429a (1), paragraph (d) of CRR, only claims on central governments, regional governments, local authorities or public sector entities in relation to public sector investments and promotional loans are exempt from Leverage ratio exposure where the institution is a public development credit institution, the exposures arising from assets that constitute claims on central governments, regional governments, local authorities or public sector entities in relation to public sector investments and promotional loans.

In C40 report, ITS mentions that this part of the reporting collects data on an alternative treatment of derivatives, SFTs, off-balance sheet items, exempted public sector investments and exempted exposures to promotional loans.

In C40 report also only exempted exposures to promotional loans are to be reported.

That is claims on central governments, regional governments, local authorities or public sector entities only are to be reported in C40 report also.

Row 0350 of C40 report requirement

Promotional loans - Claims on non-financial corporations - Accounting balance sheet value

Where the institution is a public development credit institution, the accounting balance sheet value under the applicable accounting framework of assets that constitute claims on non-financial corporations in relation to promotional loans

Row 0360 of C40 report requirement

Promotional loans - Claims on households - Accounting balance sheet value

Where the institution is a public development credit institution, the accounting balance sheet value under the applicable accounting framework of assets that constitute claims on households in relation to promotional loans

 As the only exposures to promotional exempt are to be reported in C40 also. However these two rows 0350 and 0360 of C40 report requirements are not in cosistence with the article 429a (1) (d) and (e) also. Please clarify.

Background on the question

As per Article 429a (1) (d), exposures to promotional loans  to central governments, regional government, local authorities or public sector are only to be exempt from leverage ratio.

(e) where the institution is not a public development credit institution, the parts of exposures arising from passing-through promotional loans to other credit institutions.

In the C40 report, there are two rows 0350 and 0360 which require promotional loans as claims on non-finance corporation and household entities.  These are corporate and retail exposure clasess.

This leads to inconsistency in reporting requirements of C40.

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question