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FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope

FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope : we understand that the scope to be considered for the templates 40.1 and 40.2 is the Accounting Group (including insurance companies for example) and not the CRR Group (excluding insurance company for example). Can you confirm this point ?

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 (as amended)

ID: 2013_92 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - Contents of template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" et Column 050 "other related parties"

FINREP - Template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" and Column 050 "other related parties" : can you confirm that the column 020 "subsidiaries" includes transactions with "sister entities" ?

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 (as amended)

ID: 2013_91 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - Contents of template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]"

FINREP - Template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]" : for this row, the ITS refers to "products issued by entities outside the Group" -> Which level of Group has to be considered : Accounting Group (including insurance companies for example) or CRR Group (excluding insurance companies for example) ?

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 (as amended)

ID: 2013_90 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts"

FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts" : does the row 170 "liabilities under insurance and reinsurance contracts" include insurance company technical reserves?

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 (as amended)

ID: 2013_89 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - Contents of template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets"

FINREP - Template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets" : on which row do we have to set amounts linked to "other non financial assets" and reported on row 570 "other" in template 2 ?

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 (as amended)

ID: 2013_88 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F16.7 Impairment on financial and non-financial assets - "Impairment or (-) reversal of impairment of investments in subsidaries, joint ventures and associates" (Rows 070 à 090)

FINREP - Template 16.7 Impairment on financial and non-financial assets - "Impairment or (-) reversal of impairment of investments in subsidaries, joint ventures and associates" (Rows 070 à 090) : in spite of the reference to IAS 28, we presume that the row 080 "joint ventures" anticipates IFRS 11 (with the end of proportionally consolidation). But we don't understand what is expected on the row 070 "subsidiaries" : these one are all fully consolidated and not with the equity method.

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 (as amended)

ID: 2013_87 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - Template 16.1 Interest income and expenses by instrument and counterparty sector (+ template 2) - Setting of interests on derivatives - hedge accounting other than interest rate risk

FINREP - Template 16.1 Interest income and expenses by instrument and counterparty sector (+ template 2) - Setting of interests on derivatives - hedge accounting other than interest rate risk : concerning interest on derivatives held for hedge accounting other than interest rate risk, we wonder about their setting: - we understand they are not included in template 16.1 ; can you confirm this point ? - on which row of template 2 "statement of profit or loss" should they be included ? We foresee to include them on row "other assets" (row 080) and "other liabilities" (row 140). Is it correct?

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 (as amended)

ID: 2013_86 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP: F14 Fair value hierarchy: financial instruments at fair value - Columns 060 to 080 "Accumulated change in fair value before taxes"

FINREP - Contents of template 14 Fair value hierarchy: financial instruments at fair value - Columns 060 to 080 "Accumulated change in fair value before taxes" : do gains and losses to be reported in columns 060 to 080 include only gains and losses accounted in the statement of profit or loss (like columns 040 and 050) or do they also include gains and losses accounted in "statement of comprehensive statement" ?

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 (as amended)

ID: 2013_85 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F13.1 Breakdown of loans and advances by collateral and guarantees - Col 030 "Other collateralized loans - Cash [Debt instruments issued]"

FINREP - Template 13.1 Breakdown of loans and advances by collateral and guarantees - Col 030 "Other collateralized loans - Cash [Debt instruments issued]" : ITS 81b indicates that Column 030 includes "pledges of debt securities issued by the institution". We don't understand the reference to "debts securities issued by the institution" : an institution secure its loans with securities issued by other issuers but not with its own securities; moreover, CRR Article 197 is referring to debt securities issued by different issuers but not to debt securities issued by the institution. Can you explain this?

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 (as amended)

ID: 2013_84 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP: F12 Movements in allowances for credit losses and impairment of equity instruments - Col 020 to 060 - Breakdown by counterparty

FINREP - Template 12 Movements in allowances for credit losses and impairment of equity instruments - Col 020 to 060 - Breakdown by counterparty : the breakdown by counterparty of "variation flows" columns (columns 020 to 060) is heavy - does EBA allow that institutions make this breakdown only on "closing balance" column (col 070) as it tolerates for similar template FIN 30B in current FINREP?

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 (as amended)

ID: 2013_83 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F10 Derivatives - Trading - "Economic hedges" (Rows 020, 080, 140, 200, 260 and 280)

FINREP - Template 10 Derivatives - Trading - "Economic hedges" (Rows 020, 080, 140, 200, 260 and 280) - can you confirm that this row shall include "mechanically" all derivatives classified as "held for trading" in accountancy but that are not part of the trading book as defined in CRR (excepted derivatives for proprietary trading) ?

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 (as amended)

ID: 2013_82 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F8.1 Breakdown of financial liabilities by product and by counterparty sector - "Repurchase agreements" (Rows 100, 150, 200, 250, 300 and 350)

FINREP - Template 8.1 Breakdown of financial liabilities by product and by counterparty sector - "Repurchase agreements" (Rows 100, 150, 200, 250, 300 and 350) - can you confirm that the rows "Repurchase agreement" do not include assets pledged that are not securities?

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 (as amended)

ID: 2013_81 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 310 "project finance loans"

FINREP - Template 7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 310 "project finance loans" : does this row include all "specialised lending exposures" (CRR art 147.8) or only the subcategory "project finance loans" ? Indeed, the European directive 2006-048 (art 86 al 6) mentioned "specialised lending exposures", but in the French version, a breakdown by sub-category had been added : objects lending, commodities lending, real estate financing and project finance loans ?

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 (as amended)

ID: 2013_80 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 260 "Advances that are not loans"

FINREP - Template 7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 260 "Advances that are not loans" : does this row include advances in associates current accounts (which are advances and not loans) ?

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 (as amended)

ID: 2013_79 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 200 "On demand [call] and short notice [current account]"

FINREP - Template 7 Financial assets subject to impairment that are past due or impaired (+ template 5) - Row 200 "On demand [call] and short notice [current account]" / does this row include discounts on debts that have been restructured due to counterparty default ?

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 (as amended)

ID: 2013_78 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP - F7 Financial assets subject to impairment that are past due or impaired - Column 110 "Accumulated write-offs"

Does this row include discounts on debts that have been restructured due to counterparty default ?

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 (as amended)

ID: 2013_77 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

FINREP: F1.3 Equity - Row 070 "Other equity instruments issued"

What kind of instrument is expected on this row ? Does it include all "own funds instruments" in CRR regulation, i.e. "capital instruments issued by the institution that qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 instruments"?

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 (as amended)

ID: 2013_75 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 26/07/2013

COREP: C05.01 Transitional Adjustments Reciprocal Cross Holdings - Residual amounts of CET1 to be deducted from AT1 and T2

(CA5;240 to 330;*) cover Reciprocal Cross Holdings. In CA5, for each of the capital groups (CET1, AT1 and T2), a differentiation is made between Rec. Cross Holdings where the institution has a significant investment versus a non-significant investment. In article 472 (9), it is stated that in case of a significant investment under Rec. Cross Holdings, the residual amount should be treated in accordance with point (i) of Article 36 (1) whereas for non-significant investments under Reciprocal Cross Holdings, it should be treated in accordance with point (h) of Article 36 (1). However, as both significant and non-significant holdings are treated separately in CA 5.1 (Row 390 to 420 and Row 340 to 370 respectively), we are wondering which residual amount there remains to be put under a transitional adjustment under rows 260 to 330 for columns 020 to 030.

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 (as amended)

ID: 2013_74 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 25/07/2013

FINREP: Reporting of insurance subsidiaries

According to new Finrep instructions templates F 1.1/1.2/1.3 should be reported according to the CRR scope of consolidation and template F17 according to the IFRS scope of consolidation. 1)Does this mean all tables (except template F17) should be reported according to CRR scope (which excludes insurance subsidiaries)? 2)CRR scope: Although insurance subsidiaries should not be consolidated according to the instructions, we assume the investments in and intercompany positions with insurance subsidiaries and the related P&L components with/from these subsidiaries should be reported somewhere in the consolidated figures. Is that correct? If yes, which lines in templates F 1.1-1.3 (balance sheet) and template F2 (P&L) should we use for this purpose?

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 (as amended)

ID: 2013_70 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 19/07/2013

The meaning of the "amount owed to the institution"

How should institutions understand the "amount owed to the institution" under Article 501(2)(c)(1) in case of off-balance sheet exposures to customers that haven’t yet been used? Is it the exposure value (as understood in Article 111) or the nominal value of such product (for example credit line)?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2013_416 | Topic: Credit risk | Date of submission: 21/10/2013