Question ID
2023_6813
Legal act
Directive 2013/36/EU (CRD)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
EBA VR Taxo v3.2.1, Validation rule v7872_m; EBA VR Taxo v3.2.1, Validation rulev7873_m; EBA VR Taxo v3.2.1, Validation rulev7874_m; EBA VR Taxo v3.2.1, Validation rulev7875_m; EBA VR Taxo v3.2.1, Validation rulev7876_m; EBA VR Taxo v3.2.1, Validation rul
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
Not applicable
Type of submitter
Credit institution
Subject matter
EBA VR v7872_m; v7873_m; v7874_m; v7875_m; v7876_m; v7877_m
Question

Why there is still some validation rules which control if Financial Garantee and Collateral are less than the Gross Carrying Amount in FINREP 18.02?

Background on the question

There is several validation rules which obliged us to declare Financial Garantee and Collateral less than the Gross Carrying Amount in FIN 18.02. There is multiple business cases where we can have Financial garantee and collateral more than gross carrying amount. And no regulatory text which support this validation rules.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is already explained or addressed in Annex V, Part 2, paragraph 239xi of Commission Implementing Regulation (EU) 2021/451 of 17 December 2020 where it is stated that: 'Information on collateral received and financial guarantees received on loans shall be reported in accordance with paragraph 239 of this Part. Consequently, the sum of the amounts reported for both collateral and guarantees shall be capped at the carrying amount of the related exposure'.

For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'. 

Status
Rejected question