Question ID:
2014_718
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Topic:
Supervisory reporting - Asset Encumbrance
Article:
100
Paragraph:
0
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph:
2 / Part A
Disclose name of institution / entity:
Yes
Name of institution / submitter:
Societe Generale
Country of incorporation / residence:
France
Type of submitter:
Credit institution
Subject Matter:
How to report reverse repo operations in Part A template AE-ASS (C 31.01) and/or AE-COLL (C 32.02)
Question:
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)
Background on the question:
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)
Date of submission:
10/01/2014
Published as Final Q&A:
30/04/2014
EBA Answer:

The amount of the finance granted in a 'reverse repo' should be reported in C 32.01 (AE-ASS template) as a non-encumbered loan. The collateral received in this 'reverse repo' transaction should be reported in C 32.02 (AE-COLL template).

When it is reused, the collateral received in this transaction should be reclassified as encumbered on template AE-COLL. The encumbrance of the collateral received in a 'reverse repo' transaction do not change the classification of the loan (to which is associated) as non-encumbered in template AE-ASS.

DISCLAIMER:

The present Q&A on Supervisory reporting is provisional. It will be reviewed after the respective Implementing Regulation is in and published in the Official Journal, which may differ from the text of the relevant draft ITS to which  it relates.

Status:
Final Q&A
Answer prepared by:
Answer prepared by the EBA.
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