2024_7095 Maximum amount of the collateral or guarantee that can be considered in F 13.01 and F 18.00 | European Banking Authority Skip to main content
European Banking Authority logo
  • Extranet
  • Log in
  • About us
    Back

    About us

    The EBA is an independent EU Authority.  We play a key role in safeguarding the integrity and robustness of the EU banking sector to support financial stability in the EU.

    Learn more
      • Mission, values and tasks
      • Organisation and governance
        • Governance structure and decision making
        • EBA within the EU institutional framework
        • Internal organisation
        • Accountability
      • Legal and policy framework
        • EBA regulation and institutional framework
        • Compliance with EBA regulatory products
      • Sustainable EBA
      • Diversity and inclusion
      • Careers
        • Vacancies
        • Meet our team
      • Budget
      • Procurement
    Close menu panel
  • Activities
    Back

    Activities

    To contribute to the stability and effectiveness of the European financial system, the EBA develops harmonised rules for financial institutions, promotes convergence of supervisory practices, monitors, and advises on the impact of financial innovation and the transition to sustainable finance.

    Start here
      • Single Rulebook
      • Implementing Basel III in Europe
      • Supervisory convergence
        • Supervisory convergence
        • Supervisory disclosure
        • Peer Reviews
        • Mediation
        • Breach of Union Law
        • Colleges
        • Training
      • Direct supervision and oversight
        • Markets in Crypto-assets
        • Digital operational resilience Act
      • Information for consumers
        • National competent authorities for consumer protection
        • How to complain
        • Personal finance at the EU level
        • Warnings
        • Financial education
        • National registers and national authorities responsible for handling complaints related to credit servicers
        • Frauds and scams
      • Research Workshops
      • Ad hoc activities
        • Our response to Covid-19
        • Brexit
    Close menu panel
  • Risk and data analysis
    Back

    Risk and data analysis

    To ensure the orderly functioning and stability of the financial system in the European Union, we monitor and analyse risks and vulnerabilities relevant for the regulation of banks and investment firms. We also facilitate information sharing among authorities and institutions through supervisory reporting and data disclosure.

    Learn more
      • Risk analysis
        • 2024 EU wide transparency exercise
        • EU-wide stress testing
        • Risk monitoring
        • Thematic analysis
      • Remuneration and diversity analysis
      • Pillar 3 data hub
      • Reporting
        • Reporting frameworks
        • Reporting Time Traveller
        • DPM data dictionary
        • Integrated reporting
        • Joint Bank Reporting Committee (JBRC)
      • Data
        • Registers and other list of institutions
        • Guides on data
        • Aggregate statistical data
        • Secondary reporting: data from Competent Authorities to the EBA
        • Data analytics tools
    Close menu panel
  • Publications and media
    Back

    Publications and media

    Communicating to all our audiences in the most effective way and using the most appropriate channels is crucial for us. Through our publications, announcements, and participation in external events, we are committed to reaching out to all our stakeholders to report about our policies, activities, and initiatives.

    Learn more
      • Publications
        • Guidelines
        • Regulatory Technical Standards
        • Implementing Technical Standards
        • Reports
        • Consultation papers
        • Opinions
        • Decisions
        • Staff papers
        • Annual reports
      • Press releases
      • Speeches
      • Interviews
      • Events
      • Media centre
        • Media gallery
        • Media resources
    Close menu panel

Breadcrumb

  1. Home
  2. Single Rulebook Q&A
  3. 2024_7095 Maximum amount of the collateral or guarantee that can be considered in F 13.01 and F 18.00
Question ID
2024_7095
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex V
Type of submitter
Credit institution
Subject matter
Maximum amount of the collateral or guarantee that can be considered in F 13.01 and F 18.00
Question

Could you please more precisely clarify what should be used for “Maximum amount of the collateral or guarantee that can be considered”?

  1. Primarily use Market value of collateral as it is prescribed in ESRB Recommendation? or 
  2. Each Institute can have individual approach, where Internal collateral value (Market value of the assets reduced by a certain percentage => the “haircut”) also can be primarily used?
Background on the question

For us is clearly understandable that for Template F 05.01, and related templates which are referred to Annex V Part II, paragraph 86 Market value of collateral (assessed by an independent external or internal appraiser) primarily should be used, because it is defined in ESRB Recommendation on closing real estate data gaps.

Annex V, Part II, paragraph 86:

Loans and advances shall be classified on the basis of the collateral received as follows:

(a) ‘Loans collateralized by immovable property’ shall include loans and advances formally secured by residential or commercial immovable property collateral, regardless of their loan/collateral ratio (commonly referred as ‘loan-to-value’) and the legal form of the collateral;

(b) ‘Other collateralized loans’ shall include loans and advances formally secured by collateral, regardless of their loan/collateral ratio (commonly referred to as ‘loan-to-value’ (LTV) ratio) and the legal form of the collateral, other than ‘Loans collateralised by immovable property’. That collateral shall include pledges of securities, cash, and other collateral, regardless of the legal form of the collateral.

ESRB Recommendation:

The current loan-to-value ratio LTV-C = LC / VC

Where based on Annex IV of these Recommendation, for the purpose of the calculation, ‘VC’:

a) Reflects the changes in the value of ‘V’, as defined in Section 1(3), since the most recent valuation of the property. The current value of the property should be assessed by an independent external or internal appraiser. If such assessment is not available, the current value of the property can be estimated using a granular real estate value index (e.g. based on transaction data). If such a real estate value index is also not available, a granular real estate price index can be used after application of a suitably chosen mark-down to account for the depreciation of the property. Any real estate value or price index should be sufficiently differentiated according to the geographical location of the property and the property type.

(b) Is adjusted for changes in the prior liens on the property.

(c) Is computed annually.

 

But for us is not clearly understandable which value should be used for F 13.01 and F 18.00? 

Based on Annex V, Part II, paragraph 172 “In template 13.1, the ‘maximum amount of the collateral or guarantee that can be considered’ shall be reported. The sum of the amounts of the financial guarantee and/or collateral shown in the related columns of template 13.1 shall not exceed the carrying amount of the related loan.”

Also based on Annex V, Part II, paragraph 239. Information on collateral held and guarantees received on performing and non-performing exposures shall be reported separately. Amounts reported for collateral received and guarantees received shall be calculated in accordance with paragraphs 172 and 174of this Part. The sum of the amounts reported for both collateral and guarantees shall be capped at the carrying amount or nominal amount after deduction of provisions of the related exposure.

Could you please give your opinion shall we for F 13.01 and F 18.00:

  1. Primarily use Market value of collateral as it is prescribed in ESRB Recommendation? or 
  2. Each Institute can have individual approach, where Internal collateral value (Market value of the assets reduced by a certain percentage => the “haircut”) also can be primarily used?
Submission date
28/05/2024
Rejected publishing date
14/06/2024
Rationale for rejection

This question has been rejected because the issue it deals with is already addressed in in Part 2, Annex V, paragraph 119 of of Commission Implementing Regulation (EU) 2021/451 (definition of 'Maximum amount of the guarantee that can be considered').

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

Footer

EUROPEAN BANKING AUTHORITY

Our mission is to contribute to the stability and effectiveness of the European financial system through simple, consistent, transparent, fair regulation and supervision that benefits all EU citizens.


UE logoAn agency of the EU

EU Agencies Network logoEU Agencies Network

EMAS logoSustainable EBA

Contact us

  • Contacts
  • Ask a general question
  • Send a press query
  • Ask a regulatory question
  • File a complaint
  • Whistleblower reports

Stay up to date with our work

  • Subscribe to our email alerts
  • News & press RSS feed

Follow us on Social media

  • Bluesky
  • LinkedIn
  • X
  • YouTube

Find out about us

  • The EBA at a glance
  • Vacancies
  • Privacy policy
  • Legal notice
  • Cookies policy
  • Frauds and scams

Explore related sites

  • EIOPA
  • ESMA
  • ESRB
  • CEBS archive