- Question ID
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2024_7240
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Supervisory reporting - FINREP (incl. FB&NPE)
- Article
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430
- Paragraph
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FINREP Guidance
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
- Article/Paragraph
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FINREP Guidance
- Type of submitter
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Other
- Subject matter
-
FINREP Templates F25 and F13
- Question
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It has come to our attention that Form F25.01.a contains data elements that overlap with Form F13.3.1. For instance, F25.01.a Row 0120 Column 0030 shares data with F13.3.1a Row 0020 Column 0010.
From a business perspective, this inclusion appears incongruous, and we would appreciate an explanation of the rationale behind this decision.
Could you please provide the logic and reasoning for including this shared data element between Form F25 and Form F13?
- Background on the question
-
In our recent review of regulatory reporting requirements, we identified that certain data points are shared between Form F25.01.a and Form F13.3.1. Specifically, we noted that the data in Form F25.01.a Row 0120 Column 0030 is identical to that in Form F13.3.1a Row 0020 Column 0010. While we understand the importance of comprehensive reporting, this duplication appears to create potential inefficiencies and raises questions about the intended use of this shared information across different reporting contexts.
Question: Could you please provide the logic and reasoning behind the decision to include this shared data fact between Form F25 and Form F13? We are particularly interested in understanding:
1. The regulatory purpose for including this information in both forms
2. How this shared data is used differently in the context of each form
3. Whether this duplication serves a specific compliance or risk assessment function
We believe that understanding the rationale behind this reporting structure will help us ensure more accurate and meaningful compliance with regulatory requirements. - Submission date
- Rejected publishing date
-
- Rationale for rejection
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This question has been rejected because the issue it deals with is already explained or addressed in Commission Implementing Regulation (EU) 2021/451, article 11, second paragraph, letter (g). More specifically, the information specified in template F 25 are requested only if the conditions under (i) and (ii) of such Article 11 (2) are met.
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- Status
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Rejected question