Question ID
2025_7664
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - COREP (incl. IP Losses)
Article
v4456_m
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
Article/Paragraph
v1672_m
Type of submitter
Other
Subject matter
Validation rules taxonomy V4.0 C_47.00, C_43.00.a, C_43.00.b, C_43.00.c - v4456_m
Question

Validation rule v4456_m is a consistency check between the total leverage exposure value before "Asset amount deducted - Tier 1 capital" in C 47.00 (LRCalc) and exposure values reported in C 43.00.a/b/c:

sum ({tC_47.00, r0010-0269, c0010}) + {tC_47.00, r0900, c0010} + {tC_47.00, r0910, c0010} = sum ({tC_43.00.a, (r0010, r0040, r0050, r0060, r0065, r0070), c0010}) + sum ({tC_43.00.b, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0010}) + sum ({tC_43.00.c, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0020})

Validation rule v4456_m and the instructions provided by the EBA for forms LR4 and LRCalc are inconsistent with respect to “General credit risk adjustments to off balance sheet items” (LRCalc row 0181) and “Excluded guaranteed parts of exposures arising from export credits” (if related to off balance sheet exposures, part of LRCalc row 0252).

Please provide instructions in which row(s) the amounts in LRCalc in rows 0181 and 0252 (if related to off balance sheet exposures) should be reflected in form LR4.

Background on the question

According to the instructions for LRCalc, rows 0150 to 0180 ("Off-balance sheet items with a 20% / 40% / 50% / 100% CCF  in accordance with Article 429f CRR") should be gross of the negative amounts reported in rows 0181 (“General credit risk adjustments to off balance sheet items”) and “Excluded guaranteed parts of exposures arising from export credits” (if related to off-B/S items, part of LRCALC row 0252):
Quoting instructions:
0181: "The amount reported shall not be taken into account as a reduction in the calculation of off-balance sheet items reported in rows from {0150;0010} to {0180;0010}."
0252: "The amount reported shall also be included in the applicable cells above as if no exemption applied"

Note: EBA Q&A 2020_5627 confirms that amounts reported in row 0252 of LRCalc can be also be related to off-B/S items.

Furthermore, the instructions for LR4 require that {LR4;0010;0010} is sum of {LRCalc;0150;0010}, {LRCalc;0160;0010}, {LRCalc;0165;0010}, {LRCalc;0170;0010} and {LRCalc;0180;0010}.

 

Submission date
Final publishing date
Final answer

In the C 43.00 (LR4) template, 'general credit risk adjustments to off‑balance‑sheet items' and “Excluded guaranteed parts of exposures arising from export credits” are not reported in a dedicated row. They reduce the on‑ and off‑balance‑sheet exposure categories to which they relate.

In accordance with Q&A 2020_5627 the treatment of exposures in accordance with Article 429a(1)(f) CRR can also apply to off balance sheet items if all applicable preconditions are met. Consequently, the amounts reported in {C 47.00, r0150/r0160/r0165/r0170/r0180, c0010} should be calculated gross of excluded guaranteed parts of off balance sheet exposures arising from export credits {C 47.00, r0252, c0010} and general credit risk adjustments to off balance sheet items {C 47.00, r0181, c0010}. 

EBA will adjust the instructions for {C 43.00, r0010, c0010} to make it clear that the value reported therein may differ from the sum of reported values for off balance sheet items in C 47.00 rows 0150-0180. 

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

Disclaimer

The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.