Question ID
2026_7698
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
438
Paragraph
(d), (da)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
Regulation 2024/3172 (ITS on Disclosure) - Annex I and II
Type of submitter
Credit institution
Subject matter
EBA mapping file for Pillar 3 template EU CMS2
Question

The mapping file for EU CMS2 template seems to contain multiple issues:

1) The Naming of the row EU 7a does not conform to the regulation 2024/3172 (ITS). In the ITS, the row is not an ‘of which’ row, but an independent row.


2) The row 6.2 (Of which: Retail - Secured by residential real estate) appears to be redundant. Following the ITS instructions for this section, “Where the IRB exposures would have been allocated in a different exposure class in the standardised approach (SA), the IRB exposures shall be excluded from their IRB exposure classes and they shall be disclosed   in one of the following exposure classes of the Standardised approach”. All exposures (partially) secured by real estate must be disclosed on row EU 7a or EU 7c , no exposure can be disclosed on row 6.2, which is an ‘of which’ category of row 6 (Retail). The mapping to COREP C10 row 0170 appears incorrect as it conflicts with the ITS instruction to reclass the exposures.

 

Background on the question

The mapping provided for row EU 7a for columns d and EU d appear incorrectly only to capture exposures to calculated using the IRB approach (mapping to C10 template) and ignore the part of exposures calculated using the SA (no mapping to C07 template).

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the matter it refers to has already been identified and will be considered for a forthcoming version of the Pillar 3 disclosures framework.

Status
Rejected question