- Question ID
-
2024_7026
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Supervisory reporting - FINREP (incl. FB&NPE)
- Article
-
Annex V, Art 174
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
- Article/Paragraph
-
Annex V, Art 174
- Type of submitter
-
Consultancy firm
- Subject matter
-
Reporting of the collateral and guarantees by loans and advances
- Question
-
Article 174 from Annex V mentions that where the ‘Maximum collateral/guarantee that can be considered’ exceeds the value of immovable property collateral, its remaining value shall be allocated to other collateral types and guarantees according to its quality, starting from the one with best quality. There are no details regarding the expectation of reporting for different types of collaterals used at the same time to cover different types of loan and advances if the amount of the collaterals is smaller than the total exposure covered (n:m relationships). It is not clear how the collateral should be split between the loans (if a particular order should be followed or an optimization model should be used) and if for immovable properties the prior liens are deducted from the property value before the maximum amount is calculated.
Example for F 13.01:
Residential immovable property = 100.000
Prior lien on the property = 20.000
Financial guarantee received = 10.000
Loan 1 to a non-financial corporation = 70.000
Loan 2 to other financial corporation = 60.000
Both loans are covered by the immovable property and the financial guarantee.
Position 0010/0010 F 13.01: 100.000 or 80.000 (after the prior lien is deducted)
Position 0010/0050 F 13.01: 10.000
Which amounts are expected in rows 0010, 0020 and 0030, columns 0010/0050 from F 13.01?
- Background on the question
-
The unclarity in the reporting of complex constellations of collaterals allows for different interpretations and cause differences in the reporting of the same situation by the reporting entities.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the matter it refers to has been answered in Q&A 6267 published on the EBA website.
- Status
-
Rejected question