Question ID
2025_7554
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
Point (l) of Article 439 referring to point (g) of Article 452
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
Article/Paragraph
14(d) Article 13 of ITS with regard public disclosures of the information referred to in Titles II and III of Part Eight of Regulation (EU) No 575/2013
Type of submitter
Other
Subject matter
Inconsistency between Annotated table CODIS Pillar III and Mapping_tool_including_step_2_tc (incl equity) + Rev 4.1 review_tc
Question

How should we interpret and implement the differences between the Annotated table and the Mapping Tool referring to template CCR4 - K04.00?

Background on the question

The inconsistencies have raised the following implementation-related questions:

  • K04.00a – The Annotated Table specifies the domain qAE:qAE2(qAE) as the dynamic key, including 18 domain values (among them qAE:qx2082), each reported separately per sheet. By contrast, the Mapping Tool includes only 12 values.

    Do we need to report  on K04.00a the values corresponding to the following domain values: qAE:qx2009, qAE:qx2071, qAE:qx2072, qAE:qx2073, qAE:qx2074, qAE:qx2082 which are not indicated in the Mapping tool?

  • K04.00b – The Mapping Tool calculates the 'Total (all CCR relevant exposure classes)' row as the sum of qAE:qx2023 and qAE:qx2022. Although qAE:qx2082 is included in the K04.00a template as a separate sheet, it is not part of K04.00b, since it does not fall under either qAE:qx2023 or qAE:qx2022. As a result, the total row will not be consistent with the dynamic sheets from the K04.00a template. Is this intentional?
Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. The matter it refers to will however be considered for a forthcoming version of the mapping tool.

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. The Q&A process cannot, for example, consider issues which would require changes to the regulatory framework.

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Status
Rejected question