Template questions
- Regarding the material currencies in the F 34.00 contingent encumbrance template (Line 7): Should the currencies be specified according to ISO codes (EUR, USD, GBP, etc.) or should the currencies be left unspecified (currency 1, currency 2, etc.)? - Regarding the covered bonds issuance template: what kind of purpose serves the cover pool identifier – should this be some kind of ISIN number for the cover pool? The specifications in the accompanying instructions is a bit vague. Should a bank fill in the aggregate numbers of their outstanding covered bonds in this sheet or should the sheet be duplicated for each covered bond separately?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
ID: 2014_732 |
Topic: Supervisory reporting - Asset Encumbrance |
Date of submission: 14/01/2014 |
Date of publication: 30/04/2014
Reporting Market Value in liabilities resulting from secured lending and capital market driven transactions as defined in Article 192 (C 52.00 template)
What is the difference between Market Value in column 010 and values in columns 030, 050, 080 and 100?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2014_725 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 14/01/2014 |
Date of publication: 30/04/2014
How to report reverse repo operations in Part A template AE-ASS (C 31.01) and/or AE-COLL (C 32.02)
The instructions say that the all the assets of the reporting institution must be reported in the template AE-ASS and it corresponds to the total assets registered in the balance sheet. At the same time, they also specify that collateral which has been received by the reporting institution through a reverse repo, should be reported in the template AE-COL. A reverse repo is registered as a cash loan in the balance sheet. How should a reverse repo be reported in the Part A of the reporting: as a loan in the template AE-ASS (such as its accounting treatment) or as collateral received depending on the breakdown (eg. equity, debt security…) in the template AE-COL? Or should it be reported in the 2 templates AE-ASS and AE-COL? Please note that if a reverse repo should be reported exclusively in the template AE-COL, the row 010 of the template AE-ASS will not correspond to the total assets registered in the balance sheet (i.e. the reverse repo is reported as a loan in the balance sheet)
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
ID: 2014_718 |
Topic: Supervisory reporting - Asset Encumbrance |
Date of submission: 10/01/2014 |
Date of publication: 30/04/2014
Draft Implementing Technical Standards (ITS) on supervisory reporting under the CRR, CR IP Losses (C 15.00)
Should increase of credit risk adjustment (specific loan loss provision for credit risks) during reporting period be reflected in the reported data? Should estimated loss be reported (reporting date 30.06.2013) as 250 000 EUR or as 290 000 EUR?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2014_703 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 03/01/2014 |
Date of publication: 30/04/2014
LE1 template (C 27.00) - reporting of identification data on individual clients within groups of connected clients
In the case of exposure to the group of connected clients (with 5 clients forming a group): Does an institution have to report the identification data (LE1 template C 27.00) ) only for a group of connected clients (group data) or also for those 5 clients which form the group?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2014_701 |
Topic: Supervisory reporting - Large Exposures |
Date of submission: 03/01/2014 |
Date of publication: 30/04/2014
FINREP Table F 13.03 Collateral obtained by taking possession (tangible assets) accumulated
This question asks for a clarification of the content and the validation rules of Table F 13.03. According to the instructions in Table F 13.03 instituitions shall report the cumulative carrying amount of tangible assets obtained by taking possession of collateral that remains recognised in the balance sheet at the reference date excluding those classified as "property, plant and equipment." In Annex XV there is one validation rule which makes connection between F 13.03 and F 01.01 v1090_m {F 13.03, r010, c010}
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2013_684 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 20/12/2013 |
Date of publication: 30/04/2014
Definition of collateral for Table F32.02 and clarification of table structure
Is it correct, that rows 140-230 of table F 32.02 refer to the type of collateral received (eg. Loans on demand received as a collateral, or equity instruments received as collateral) and not to the collateralized asset class? Does collateral include all kind of risk mitigation received (Guarantees, Mortgages, Securities, Equity Instruments)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
ID: 2013_675 |
Topic: Supervisory reporting - Asset Encumbrance |
Date of submission: 19/12/2013 |
Date of publication: 30/04/2014
Disclosure of certain information by large subsidiaries of EU parent institutions on an individual or sub-consolidated basis
The disclosure information of regulatory groups is according to Article 13(1)/(2) first paragraph (each) of Regulation (EU) No. 575/2013 (CRR) to be done on a consolidated basis in any case. However, Article 13(1)/(2) second paragraph (each) of the CRR requires the disclosure of certain information by significant subsidiaries etc. as well. In the past, the implementation of that rule in Article 72 of Directive 2006/48/EC led in practice to the disclosure of only one consolidated report disclosing the required information also for all individual institutions or sub-groups which are of material significance. To our understanding, there exists a factual possibility for the entity in charge of the disclosure obligation on a consolidated level to either separately disclose the required information within one disclosure report or to take care for the issuance of separated individual disclosure reports of the significant subsidiaries and/or those subsidiaries which are of material significance for their local market. Is it possible to disclose also under CRR only a consolidated disclosure report with – in case need be – individual information per institution when requested? Is this particularly the case, where that practice has been used in the past and accepted by the national competent authorities?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2014_759 |
Topic: Transparency and Pillar 3 |
Date of submission: 23/01/2014 |
Date of publication: 30/04/2014
Capital deductions
The NSFR return (tab 60) requires us to report in row 1310 (ID 1.13) the "assets deducted from own funds not requiring stable funding" in 'age' buckets. How do we age capital deductions?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2013_673 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 18/12/2013 |
Date of publication: 30/04/2014
Own funds requirements for commodities risk
Article 359(2) of Regulation (EU) No. 575/2013 states: “Positions in the same commodity may be offset and assigned to the appropriate maturity bands on a net basis for the following: (a) positions in contracts maturing on the same date; (b) positions in contracts maturing within 10 days of each other if the contracts are traded on markets which have daily delivery dates.” A Fair Value Option is applied to the positions in the Banking Book. The positions are hedged “back-to-back” in terms of cash flows that are exactly offsetting each other and represent thus a perfect economic hedge. Due to discounting effects positions are not however perfectly netted in terms of market values, and thus in terms of net delta weighted equivalents. Does that still mean that the institution shall assign zero values to all the maturity bands in the Table 1 referring to the Maturity ladder approach, or must the netted cash deltas be assigned to each the maturity band instead?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_589 |
Topic: Market risk |
Date of submission: 29/11/2013 |
Date of publication: 30/04/2014
Defintion of "all positions" in the templates C 18.00 - C 23.00, Market risks
What is the definition of "all postions" in the columns in the market risk templates C 18.00 -C 23.00? "All positions" are not descibed or defined neither in CRR nor in the instructions.
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2013_649 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 13/12/2013 |
Date of publication: 30/04/2014
Requirement to disclose each individual instrument in the disclosure of capital instruments' main features
For the requirement to disclose a description of the main features of the Common Equity Tier 1 and AT1 and T2 instruments issued by the institution under Article 437(1)(b) of Regulation (EU) No. 575/2013, does the disclosure template require each individual security to be disclosed in the main features template that entities are expected to produce on an external website (BCBS Composition of Capital disclosure requirements - June 2012 - Appendix III)? Would it possible to agree a "de minimis" threshold and allow small securities to be presented en masse given the same value date, maturity date and other terms and conditions?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_553 |
Topic: Own funds |
Date of submission: 22/11/2013 |
Date of publication: 30/04/2014
Grandfathered Instruments and Deduction Threshold Exemptions
When calculating the amount of Common Equity Tier 1 (CET 1) that is multiplied by 10%/17.65% for the purposes of threshold exemptions for deductions, should grandfathered instruments be included in the amount of CET1 to the extent that they qualify as CET 1 during the grandfathering period?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_527 |
Topic: Own funds |
Date of submission: 13/11/2013 |
Date of publication: 30/04/2014
Definition of exposure class "Exposures in default" under SA approach
Are all exposures of the defaulted obligor taken into account when assigning exposures into the exposure class "Exposures in default" or just individual exposure(s) of that obligor that is (are) in default, since the definition of "Exposures in default" has changed (default definition according to the IRB approach)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_511 |
Topic: Credit risk |
Date of submission: 07/11/2013 |
Date of publication: 30/04/2014
Supervisory permission for reducing own funds if the institution replaces the instruments with own funds instruments of equal or higher quality
Are replacements of capital instruments also possible with other own funds items (e.g. retained earnings)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_467 |
Topic: Own funds |
Date of submission: 01/11/2013 |
Date of publication: 30/04/2014
Reconciliation between accounting and CRR scope of consolidation when no accounting scope exists
In case a bank has to provide financial information according to FINREP on a subconsolidated level, but the institution has no accounting obligation on a subconsolidated level, what should be filled in Template 17 of the FINREP-Reporting?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2013_636 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 11/12/2013 |
Date of publication: 30/04/2014
Applicable basis for determining deferred tax assets to be deducted from CET1
Is the amount of deferred tax assets and liabilities relevant for the calculation of the amount to be deducted from Common Equity Tier 1 (CET1) according to Article 36(1)(c) of Regulation (EU) No. 575/2013 (CRR) to be determined based on the accounting values of deferred tax assets and liabilities as disclosed in the balance sheet?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_258 |
Topic: Own funds |
Date of submission: 17/09/2013 |
Date of publication: 30/04/2014
Consideration of collateral in the current exposure method
We seek clarification regarding the consideration of collateral in the current exposure method (referred to as the Mark-to-market method in Regulation (EU) No 575/2013 (CRR) for the own capital requirements as well as for the large exposure regime. Is it possible to allow for collateral posted in calculating the current replacement according to Article 298(1)(c)(i) of Regulation (EU) No 575/2013 (CRR)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2013_206 |
Topic: Market risk |
Date of submission: 02/09/2013 |
Date of publication: 30/04/2014
Table F 02.00 and Table F 43.00 - cross validation of Provisions charge
FINREP Table F 02.00 subtotal row 430 (Provisions or Reversals of Provisions) is identified on the template as cross referencing to Table F 43.00 (Provisions). The cross validations do not however identify what data should agree. Please confirm which columns (and for which rows ) on Table F 43.00 should agree back to Table F 02.00.
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2013_634 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 10/12/2013 |
Date of publication: 30/04/2014
FINREP Reporting - Cumulative from ARD or period-on-period
Can the EBA please confirm whether data in the FINREP templates should be reported on a cumulative basis (from the start of the accounting reference date), or period-on-period?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
ID: 2013_619 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 04/12/2013 |
Date of publication: 30/04/2014