Single Rulebook Q&A

Question ID: 2017_3343
Legal act : Regulation (EU) No 575/2013 (CRR)
Topic : Supervisory reporting
Article: 99
Article/Paragraph : Annexes I and II, C 01.00, C 09.01
COM Delegated or Implementing Acts/EBA RTS/EBA ITS/EBA GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)
Subject matter : Reporting of credit risk adjustments according to Article 110 of CRR
  1. In relation to SA General credit risk adjustments, as per template C 01.00, row 920, column 010, is an institution also required to report the respective values in column 050 in template C 09.01?
  2. Furthermore, should this credit risk adjustment apply for a bank and the bank is not including it in its Tier 2 capital, is the NCA obliged to inform the bank accordingly?
Background on the question:
  1. No instructions are given in Annex II - Reporting on own funds and own funds requirements in this regard. We currently have institutions which are reporting in row 920, column 010 of C 01.00 without reporting in C 09.01 and there are others who report in both templates.
  2. Some institutions are not reporting in C 01.00 but according to the RTS on the calculation of credit risk adjustments, such adjustment does apply.
Date of submission: 14/06/2017
Published as Final Q&A: 24/11/2017
EBA answer:
  1. General credit risk adjustments (GCRAs) shall be reported both in templates C 01.00, row 920, column 010 and C 09.01, column 050 of Annex I to Regulation (EU) 680/2014 (ITS on Supervisory Reporting). Column 050 of template C 09.01 shall reflect the amount of GCRAs before the application of the cap of Article 62(c) of Regulation (EU) No 575/2013 (CRR), i.e. the uncapped amount.
  2. It is the responsibility of the reporting entity to determine its Tier 2 capital, under control and review of the National competent authority. The reporting entity might choose not to recognize their GCRAs in Tier 2 as this constitutes a stricter prudential measure according to Article 3 CRR.
Status: Final Q&A
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