Question ID
2024_7212
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
EBA FINREP : ANNEX V REPORTING ON FINANCIAL INFORMATION, Assets (1.1)
Paragraph
1, 5 & 6
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Article/Paragraph
EBA FINREP : ANNEX V REPORTING ON FINANCIAL INFORMATION, Assets (1.1) Para 1, 5 & 6
Type of submitter
Credit institution
Subject matter
a) Disclosure of Items in Transit balance in FINREP Table 01.01 {F01.01, c0010 (r0020 or r0183 or r0360)} b) EBA_v5013 (Type - Error): [F 05.01, F 01.01] Sum of Loans & Advances across Industry ({{F 05.01, r0080, (c0010, c0020, c0030, c0040, c0050, c0060)}}) Should be equal to Sum of Cash at Central Banks and Loans & Advances in Balance Sheet ({{F 01.01, c0010, (r0030, r0040, r0099, r0130, r0144, r0174, r0178, r0183, r0233, r0237)}})
Question

1) Disclosure of items in transit balance in FINREP Template F 01.01 {F01.01, c0010 (r0020 or r0183 or r0360)}

Please clarify where the items in transit balances should be reported in Template F01.01 out of the following?

a) Other Assets (c0010, r0360)

b) Loans & advances at amortised cost (c0010, r0183) 

c) Cash on hand (c0010, r0020).

2) EBA_v5013 (Type - Error): [F 05.01, F 01.01] sum of Loans & Advances across Industry ({{F 05.01, r0080, (c0010, c0020, c0030, c0040, c0050, c0060)}}) should be equal to sum of Cash at Central Banks and Loans & Advances in Balance Sheet ({{F 01.01, c0010, (r0030, r0040, r0099, r0130, r0144, r0174, r0178, r0183, r0233, r0237)}})

Background on the question

a) There is no explicit reference provided in PRA Annex V guidance on disclosure of Items in transit in Table 1.01 (Assets) 
b) As per Para 85 (g) of Table 5 - ‘Advances that are not loans’ shall include advances that cannot be classified as loans in accordance with the Table of Part 2 of Annex II to the ECB BSI Regulation. That item shall include, among others, gross amounts receivable in respect of suspense items (such as funds that are awaiting investment, transfer, or settlement) and transit items (such as cheques and other forms of payment that have been sent for collection).
c) Contradicting to para 85(g), Guidance as per Table of Part 2 of Annex II to the ECB BSI Regulation defines Transit items within Remaining assets and thus it cannot be classified as Loans & Advances in Table F1.01
d) EBA validation V5013 does not enable retaining the balances in Other assets in Table F1.01 and reporting the Items in transit balances within Advances that are not loans 
 

Submission date
Status
Question under review
Answer prepared by
Answer prepared by the EBA.