Question ID
2024_7038
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
Paragraph
N/A
Subparagraph
N/A
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
Template 7
Type of submitter
Other
Subject matter
Val rules_v12727_m_for template 7 GAR amount is not aligned with ITS
Question

We believe the ITS instructions 2022/2453  are incorrect for Row 32 into ITS (EU) 2022/2453. NB =  equivalent row into DPM is 0320.

Background on the question

Row 32 into ITS (EU) 2022/2453 / row 0320 in DPM: “Total GAR assets: This row shall be equal to row 1 of this template.”

While this validation rules indicates we must also sum the row 0310: v12727_m: {r0320} = {r0010} + {r0310}

 

Row 310 is for “Collateral obtained by taking possession: residential and commercial immovable properties” and this type of assets must be part of the GAR numerator.

 

Validation rule v12728_m: {r0010} = {r0020} + {r0200} + {r0240} + {r0280}. 

It means row 310 is not considered into row 0010. It seems logical because row 0010 title is “Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation”.  Collateral obtained by taking possession RRE/CRE cannot fit with the title of row 0010 because if the bank has taken possession of a collateral, it is not a loan anymore, it is a physical asset from the bank.

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question