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Reporting of "instrument-by-instrument"

In table F 40.2, Annex III, the group structure should be reported instrument-by-instrument. Clarifications are needed in relation to the definition of "instrument" in the contest of Group Structure (i.e. tabel 40). Is FINREP requiring information related to each security (independently on whether the security is trading) which is held by the reporting entity at reference date?

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_344 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 07/10/2013 | Date of publication: 14/03/2014

FinRep table 5 row 010 column 030 - On demand [call] and short notice [current account]

Annex V indicates that balances receivable on demand classified as "cash and cash balances at central banks" shall also be reported in this template. This statement is supported by the validation rules stating that {F 01.01, r040, c010} = {F 5.00, r010, c030} (though only relating to other demand deposits). However, amounts in table 5 should be equal to tables 4.1 through 4.4 regarding loans and advances. This reasoning is indirectly supported by the following logical reasoning: If {F 01.01, r040, c010} = {F 5.00, r010, c030} AND if {F 01.01, r040, c010} has a detailed breakdown in table 4 as stated in Annex III, then there should be a link between table 4 and { F 5.00, r010, c030}. In which table (4.1, 4.2, 4.3, 4.4) should cash and cash balances be included? Validation rules regarding these templates don't seem to include cash and cash balances at central banks.

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_341 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 04/10/2013 | Date of publication: 14/03/2014

Taking into account insurance effect on operational risk

Recital 52 of Regulation 575/2013/EU (CRR) suggests insurance should be taken into account for the determination of own funds requirements with respect to operational risks, including in simple approaches. How can insurance be taken into account in the basic indicator and standardised approaches of operational risk?

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

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

ID: 2014_706 | Topic: Operational risk | Date of submission: 03/01/2014 | Date of publication: 14/03/2014

Financial guarantees received reported in table 9.2 and table 13.1

Should Financial Guarantees recieved reported in table 13.1 equal financial guarantees in table 9.2?

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_338 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 04/10/2013 | Date of publication: 14/03/2014

Short positions

There is no row for "short positions" in table F 16.01. According to the instructions short positions may not be included in Other financial liabilities. Where should short positions be included instead?

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_328 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 04/10/2013 | Date of publication: 14/03/2014

IFRS references of column 110 “Accumulated write-offs” of F 07.00 template

What is the meaning of the references to IAS 39 AG 84-92 provisions (related to impairment losses) in the column 110 of F 07.00 template?

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_203 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 02/09/2013 | Date of publication: 14/03/2014

Removal from the balance sheet of loans considered uncollectible (write-off in the context of the financial reporting form F 07.00)

Considering the fact that the write-off definition provided by para.49 from Part 2 of Annex V to the ITS (FINREP instructions) seems to depart from the IAS 39 derecognition principles, what did you envisage when requesting the amounts to be reported in the column 110 “Accumulated write-offs”? More specific, could you provide us examples of situations leading to filling in the column 110 “Accumulated write-offs”?

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_202 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 02/09/2013 | Date of publication: 14/03/2014

Allocation of the collective impairment allowances

In order to fill in the FINREP templates, how should be performed the allocation of the collective impairment allowances among group assets?

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_201 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 02/09/2013 | Date of publication: 14/03/2014

IRB exposure value - Recognition of specific credit risk adjustment for positions measured at fair-value (e.g. IFRS category FVO, HfT and AfS)

Which is the exposure value according to Article 166 (1) of Regulation (EU) No. 575/2013 (CRR) for IRB positions measured at fair value (to p+l or OCI) in the relevant accounting standard, when a separation of credit risk and market risk related fair value changes (e.g. revaluation reserve) for these positions is not possible and therefore not used to cover expected loss in accordance with Article 159 of the CRR?

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

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

ID: 2013_101 | Topic: Credit risk | Date of submission: 29/07/2013 | Date of publication: 14/03/2014

Scope of LE3 template: Details of the exposures to individual clients within groups of connected clients

Is there a threshold foreseen to fill in this table? Or do we have to fill in all the exposures on individual clients, who belong to a group of connected clients?

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_394 | Topic: Supervisory reporting - Large Exposures | Date of submission: 16/10/2013 | Date of publication: 07/03/2014

Geographical breakdown of CR IP Losses

Is there a threshold foreseen to fill in the template by country? Or do we need to give the data by each country (even if it is not material)?

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_393 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 16/10/2013 | Date of publication: 07/03/2014

Reporting of information with geographical breakdown

Is there a threshold foreseen to report a country, or do we need to send the information for all the countries on which we have an exposure?

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_391 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 16/10/2013 | Date of publication: 07/03/2014

ITS reporting - Group Solvency - Applicable only at top conso level

Could you confirm that this table is applicable only at top conso level only, ie it is not required to report this in sub-consolidated reports

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_377 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 10/10/2013 | Date of publication: 07/03/2014

OPR Details

a)Could you provide an explanation to the reference to Article 5 point (b) (2) iii in paragraph 124 of the COREP instructions (operational risk details template)? b)Is EBA going to publish every year the sum of individual balance sheet totals of all institutions within a Member State or should we ask this information from the national supervisor? c)Article 6 of the ‘Draft ITS on supervisory reporting’ refers to article 4. Is this correct? d)If the ratio of individual balance sheet total on the sum of individual balance sheet totals of all institutions within the same Member State is higher than or equal to 1% over the first reporting period (Q1 2014), some information about operational losses has to be reported. Is this a correct interpretation of the entry criteria mentioned in article 4 of the ‘Draft ITS on supervisory 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 (as amended)

ID: 2013_362 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 08/10/2013 | Date of publication: 07/03/2014

Error on ID / Template C01.00 - Own Funds (CA1), row 780

Why row 780 has not the same ID between Excel file (Annex I - Own funds templates) and Word file (Annex II - Own funds) ?

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_349 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 07/10/2013 | Date of publication: 07/03/2014

Distribution in columns 040-070 in Geographical Breakdown

Are the columns 040-070 memorandum items in the same way (the figure should be reported where the obligors would have been reported if those exposures were not in assigned to “in default”) that column 020 is?

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_347 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 07/10/2013 | Date of publication: 07/03/2014

Memorandum items in credit risk SA

Can you please confirm that the memorandum items in row 290-320 only should be filled in within exposure classes mentioned under point 54 (annex II, 3.2.1) and the Total template? I.e. that those rows should be empty in the exposure classes “in default” and "secured by immovable property”.

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_346 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 07/10/2013 | Date of publication: 07/03/2014

Allocating the FX differences as a result of subsidiaries' consolidation

Table 46 requires the reconciliation of opening and closing balances for equity account, which is also a requirement under IFRS. Usually banks with foreign subsidiary operations have a separate line item in the IFRS reconciliation reporting to record the effects of FX reconversion of the subsidiaries. The line to account for the FX difference is missing in FINREP table 46. Where should FX differences be reported?

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_345 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 07/10/2013 | Date of publication: 07/03/2014

Link between table 1.1 and tables 4.1 to 4.4

"The link between table 1.1, ""cash balances at central banks"" and ""other demand"" deposits"" and tables ""4.1 to 4.4"" is not clear to us. (1) On the one hand, table 1.1, line 30 (""cash balances at central banks"") and line 40 (""other demand deposits""), have a detailed breakdown in table 4 according to Annex III. (2) On the other hand, Annex V (part I.12) states that “accounting portfolios”, meaning financial instruments aggregated by valuation rules, as they are delineated in tables 4.1 to 4.4, do not include ""cash and cash balances at central bank"". This statement is supported by the missing rules between table 1.1, line 30 and line 40 and table 4. In our opinion, these two facts represent a contradiction."

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_339 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 04/10/2013 | Date of publication: 07/03/2014

Reporting thresholds - entry and exit criteria

Institution shall start reporting information subject to thresholds from the next reporting reference date where they have exceeded the threshold on two consecutive reporting reference dates. Is our understanding correct that if an institution exceeded the thresholds as of December 31 an September 30 the first reporting should be submitted for the reference date December 31? Institutions may stop reporting information subject to thresholds from the next reporting reference date where they have fallen below the relevant thresholds on three consecutive reporting reference dates. Based on the same methodology we assume that if an institution has fallen below the thresholds as of December 31, September 30 and June 30 no reporting is required as of December 31. Is our understanding 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_337 | Topic: Supervisory reporting - Other | Date of submission: 04/10/2013 | Date of publication: 07/03/2014