Question ID
2014_1256
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Large Exposures
Article
394
Paragraph
1
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph
ANNEX IX PART II 1.4
Name of institution / submitter
Banque Internationale à Luxembourg
Country of incorporation / residence
Luxembourg
Type of submitter
Credit institution
Subject matter
Report information on the 20 largest exposures to clients or groups of connected clients
Question

An institution has to report information on its large exposure, on its 10 largest exposures to institutions as well as on the 10 largest exposures to unregulated financial entities according to Article 394 . Furthermore, an IRBA institution also has to report its 20 largest exposures sorted by the non exempted exposure value (resulting from subtracting the amount in column 320 ‘Amounts exempted’ of template LE2 from the amount in column 210 ‘Total’ of that same template, according to annex IX). In case the institution has already reported some of these 20 counterparts as large exposure or in one of the two TOP 10, does this institution: -have not report those who are already reported in the same template ? -have to complete the template with the next ones in order to report a total of 20 largest exposures ?

Background on the question

In order to report information on the 20 largest exposures to clients or groups of connected clients according to the last sentence of Article 394(1) of Regulation (EU) No 575/2013 on a consolidated basis, the parent institutions in a Member State which are subject to Part three, Title II, Chapter 3 of Regula-tion (EU) No 575/2013 shall use templates LE1, LE2 and LE3. The exposure value resulting from sub-tracting the amount in column 320 (‘Amounts exempted’) of template LE2 from the amount in column 210 (‘Total’) of that same template is the amount that shall be used for determining these 20 largest exposures.

Submission date
Final publishing date
Final answer

Both questions are answered with yes.

On the first question: in case an exposure falls under the scope of several reporting requirements which are processed by means of the large exposures templates (Annex VIII of Regulation (EU) No 680/2014 13 ITS on Supervisory Reporting of institutions (ITS)) the institution needs to report the exposure only once. Hence, in the described case of an exposure which is reported in its capacity as either large exposure or one of the 10 largest exposures to institutions or unregulated financial sector entities, there is no need for a second reporting due to the capacity as one of the 20 largest exposures. The same holds true (i.e. no double reporting) with regard to possible overlaps with the reporting requirement according to Article 9 (2) (g) and Article 11 (2) (g) of the ITS on Supervisory Reporting (exposures larger or equal to 300 million EUR but less than 10% of the institution´s eligible capital) which are processed by means of the large exposure templates (C 27.00, C 28.00, C 29.00, C 30.00 and C 31.00).

On the second question: in case an exposure constitutes both, a large exposure and one of the 10 largest to institutions/unregulated financial sector entities or one of the 20 largest, the reporting requirement regarding the largest exposures is partially fulfilled by the reporting of this large exposure. The rest of the report regarding the 10 or 20 largest exposures needs to be completed with further exposures. 

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

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