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DPM 3.0 - C80.00 - C84.00 - Inconsistent modelisation and validation rules v10127_m and v10143_m.

Modelisation issue between report C80.00 and C84.00 but only for the sheets giving a breakdown per currency as we have some inconsistent duplicated fact. See background on the question.

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: 2021_6038 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 15/06/2021

DPM 3.0 validation rules for C84 total RSF

According to validation rules v10158_m and v10063_m, RSF from derivatives should not be included in total required stable funding row 10 in neither column 10 nor 20. Is this really correct? It indicates that RSF from derivatives is not included in calculating the ratio then.

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: 2021_5847 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 12/05/2021

Large Exposures : Mismatch between ITS and DPM v3.0 - C28 column 350 / C29 column 360.

The ITS states that a percentage of Tier 1 capital should be submitted for C28 column 350 / C29 column 360, whereas the DPM only permit a monetary value.

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: 2021_5814 | Topic: Supervisory reporting - Large Exposures | Date of submission: 13/04/2021

Clarification of Value Adjustments according to Art. 111 of CRR2

Should we include in the (C28.00, r010, c190) cell the amount of the valuation adjustment which will be deducted from the original exposure in C28.00 (r010, C110) according to calculations performed under article 111?

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

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

ID: 2021_5734 | Topic: Supervisory reporting - Large Exposures | Date of submission: 11/02/2021

Application of own fund requirements for position risk (CRR Title IV, Chapter 2) to net positions in securitization debt instruments

How should the effect of the cap in Article 335 CRR be reported in COREP template C 14.01 for securitization positions in the trading book?

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: 2021_5729 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 09/02/2021

FINREP V6301_m: for the rows (010;090;670) the {c010} != empty

How should small institutions, without financial cost, fill in rows 10, 90 and 670 of FI_2 to comply with validation rule v6301?

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: 2021_5705 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 27/01/2021

DPM v3.0 NSFR Derivatives

Should only derivatives with a residual maturity < 6 be reported on NSFR templates?

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

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

ID: 2021_5702 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 27/01/2021

Reporting of the Securitisation of liabilities in C_14 report (SEC DETAILS) when the ultimate underlying is originally issued by another entity than the reporting institution.

When financial liabilities are the ultimate underlying of a given securitisation and when those liabilities have originally been issued by another institution than the reporting one, how should the column c160 (type of underlying assets) 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: 2020_5661 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 17/12/2020

Follow-up question on 2019_4818 related to CB Eligible Central bank withdrawable reserve to be reported in memo line 13 C 66.

As clarified in 2019_4818 that withdrawable central bank reserve may be reported as CB eligible in C71. The same CB reserve is reported in C66 row 3.2 also as CB eligible. In C66 CB eligible HQLA are reported in memo line 13. C66 instruction has specifically mentioned to report row 3.3, 3.4 and 3.5 CB eligible values in memo line 13. As we have now agreed to report CB withdrawable reserve as CB eligible for C71 should this also be included in memo line 13 of C66 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: 2020_5646 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 08/12/2020

Reconciliation between the sum of Total Risk Exposure contributions in {C06.02;c250} and the Total Risk Exposure reported in ({C02.00;r010;c010}).

The sum of Total Risk Exposure contributions in {C06.02;c250} is not expected to differ greatly from the Total Risk Exposure reported in C02 ({C02.00;r010;c010}). However, the amount in the COREP C02 includes the RWA for entities consolidated using the equity method, while the amount in the COREP C06.02 does not, because entities consolidated using the equity method are out of the scope of this COREP. According to the reporting instructions, the entity should allocate the RWAs so that the value for the group is the sum of the values reported for each entity in ‘Group Solvency’ template. The entity consolidated using the equity method should play no role. I understand that the column 250 (and therefore columns 260 to 290) of the COREP C06.02 should not report actual risk figures, but “contributions”. According to the regulation 2014/680 Annex II paragraph 35, “The institutions shall define the most appropriate breakdown method between the entities to take into account the possible diversification effects for market risk and operational risk”. I understand that reporting entities has to split the total RWA for credit risk, market risk and operational risk (and other risks) – as reported in the COREP C02 – between entities reported in the COREP C06.02, using a breakdown method. Therefore, I understand that the “real” amount of RWA of entities consolidated using the equity method is in fine allocated to other entities. Hence, could you confirm that indeed, the amount of RWA of entities consolidated using the equity method should be allocated by the reporting entity to other entities using the “most appropriate breakdown method” in the COREP C06.02?

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: 2020_5612 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 12/11/2020

Template C32.01. Guidance required for which row to submit commodity assets and liabilities on template C32.01,

When following guidance found in AnnexII (page 185-190) there is no guidance as to where to include Commodity Assets (or liabilities) that are not derivatives (even though they are in scope for PVA threshold assessment). These are not Financial Assets or Liabilities even if fair valued and as such do not fit in any of the rows on the template. The equivalent row for assets in Finrep template 01.01 is row 360 'Other assets' but this has no equivalent in template C32.01.

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: 2018_4190 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 09/08/2018

EBA validation rule v2708_m for DPM 2.6 and 2.7

In the latest version of Annex V of Finrep IFRS9, in the Part 1 paragraph 44 (h) “the immediate counterparties shall be for loan commitments, financial guarantees and other commitments received, the GUARANTOR or the COUNTERPARTY that has provided the commitment to the reporting institution” instead of the debtor of the loan. We would like to know whether this definition refers to all Finrep ITS’ templates or only to some of them. In particular, the use of the guarantor shall apply: • only to template 9.2 “Loan commitments, financial guarantees and other commitments received” or • to template # 9.2 “Loan commitments, financial guarantees and other commitments received”, template # 18 “Information on performing and non-performing exposures” and template # 19 “Information forborne exposures”.

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: 2017_3600 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 22/11/2017

Clarification of the collateral amounts -validation rules v4759_m & v4774_m

Could you please clarify what amounts need to be reported in columns 150-210 of template C08.01, specifically, for ‘funded credit protection’ ‘real estate’ (column 190), when own estimates of LGD are used.

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: 2017_3349 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 16/06/2017

Reporting the insurance products under the item 150 of the template F 22.02 - Assets involved in the services provided

What value should be reported for the insurance products under the item 150 of the template F 22.02: the insurance premium, the banking fee or the insured amount?

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: 2014_1537 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 13/10/2014

COREP validation rule v3691

When the AT1 adjustment on Minority Interest (fully loaded) as reported in C05.01 c060; r091 is a positive figure, the transitional recognition hereon (C05.01 c020; r091) must then be negative. While the validation rules on columns 060 and 030 (resp. v3692 and v3693) have been de-activated on 23/03/14, we do not see why the validation formulae regarding column 020 (v3691) remains applicable.

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: 2014_1395 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 25/07/2014

Validation rule v3694_s - v0532_m

During the validation of the C13 and C05.02 (Corep own funds and leverage, consolidated on prudential basis we obtained a validation), performed by our regulator, we obtained a validation error that is incorrect, namely: v3694_s Sign C 05.02 (010;020;090) (020;030;040;060) {C 05.02} >= 0 do not run rule The correction in C05.02 does not only reflect the temporary inclusion of subordinated loans which don’t fulfill the requirements of CRR / CRD IV, but should also reflect the temporary transfer of old-style hybrids to AT1 in a phased approach. When the old-style hybrid instruments fulfill the conditions to be recognized as Tier 2 capital under CRR/CRD IV, these instruments are taken into account in the fully loaded reporting as reflected on line {C01.00,r760,c010). However in a phased-in calculation, which is reported under the transitional measures, these instruments can temporarily still be recognized as Additional Tier 1 instrument. Therefore, the transitional adjustment related to Tier 2 will imply a decrease of Tier 2 capital and recognition as Additional Tier 1 capital (in 2014 only 20% remain in T2 and 80% will be transferred to AT1, in 2015 40% will stay in T2 and 60% will receive recognition as AT1, …) and thus the correction to be made to Tier 2 is negative. v0532_m: (c190) = (c200) + (c210) + (c220) + (c230) + (c240) + (c250) + (c260) + (c270) + (c280) + (c290) + (c300) + (c310) + (c320) + (c330) + (c350) + (c370) [[C 13.00 (r010-150;170-540)]] (1 error(s)) We assume that validation check in table C13 on field W51 (Exposure value subject to risk weights) is erroneous. The value in this field should totalize all exposure values in the fields from X51 till AI51 (ratings based method) plus AJ51 (unrated), AK51 (supervisory formula), AM51 (look- through) and AO51 (internal assessment approach). It’s however impossible to meet this requirement, since the fields from AK51 till AQ51 are blocked.

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: 2014_1388 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 24/07/2014

Off-Balance Sheet Exposures in Templates 18 and 19 with respect to Q&A 2013_214

What are the reporting requirements for FINREP table 18 column, column 210, rows 330 – 550 and table 19 column 180, row 340?

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: 2014_1055 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 07/04/2014

Calculation of net positions under Article 327 (1)

Does a short (long) position on an over-the-counter derivative on a bond/ equity (single name/index/basket) underlying (such as a total return swap (TRS), equity swap, asset swap, etc) net off against a long (short) position in its bond/equity underlying as long as the bond/equity (single name/index/basket) underlying of the derivative contract is the same as the bond/equity in which the long (short) position exists?

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

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

ID: 2018_4386 | Topic: Market risk | Date of submission: 22/11/2018

F 33.00 - MATURITY DATA (AE-MAT) - Maturity of the encumbered asset

How to report initial margin (IM) and variable margin (VM) under F33 Maturity data report - 010-encumbered assets? Given there is no clear guidance on this particular maturity reporting therefore it is grateful if EBA could provide a clearer guidance or best practice on this issue.

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: 2015_2060 | Topic: Supervisory reporting - Asset Encumbrance | Date of submission: 23/06/2015

Reporting of 'Sources of encumbrance' in line with F32.04

As part of the reporting of asset encumbrance, institutions are required to report its 'Sources of encumbrance' within template F32.04. Our question relates to this template, and deals specifically with deposits. One of the sources of asset encumbrance are deposits that are eligible for the Depositor Compensation Scheme (DCS). The instructions of F32.04, for the reporting of deposits (row 040 / 070) state that institutions are to report the "Carrying amount of the collateralized deposits of the reporting institution in so far as these deposits entail asset encumbrance for that institution". Does this imply that we are required to report the entire amount of deposits eligible for the DCS? Or up to the amount of assets pledged? As an example, suppose that an institution has €500 million of deposits which are eligible for the DCS. Under the DCS, the institution is required to pledge assets equivalent to an established % of eligible deposits. Suppose that the aggregate amount of assets which the institution is required to pledge is €5 million - consisting of €1.5 million in cash and the remaining in bonds. Given the above example, our question is: are institutions required to report the €500 million as a source of encumbrance in F32.04 column 010, row 070 "collateralized deposits other than repurchase agreements". Or the amount to be reported shall be the €5 million?

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: 2015_2022 | Topic: Supervisory reporting - Asset Encumbrance | Date of submission: 27/05/2015