Question ID
2014_1295
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - COREP (incl. IP Losses)
Article
99
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Part II, chapter 3.2.2, paragraph 53
Type of submitter
Credit institution
Subject matter
Memorandum Items in Credit Risk SA
Question

Can you please confirm that the memorandum items in row 290-320 only should 1. Include Exposures secured by immovable property under articles 124,125 and 126 2. In case of the exposure being to a "High Risk" customer that is fully secured by an eg. RRE then the in template C 07.00 - exposure class "High Risk" no memorandum items will be completed (based on point 54 of the instruction as High Risk Category is not one of them) BUT instead the original asset class of the high risk obligor eg. Corporate should be completed

Background on the question

The memorandum items in C07.00 should, according to point 53 and 55 in the instruction, only be reported in the six exposure classes that are specified. Exposure class "High Risk" is not mentioned among those six exposure classes. However, there are cases where High Risk Exposures are secured by immovable property

Submission date
Final publishing date
Final answer
Question 1The memorandum items in rows 290 to 320 of table C 07.00 of Annex I of Regulation (EU) No 680/2014 - ITS on supervisory reporting include both exposures secured by mortgages on immovable property according to Article 112 (i) of Regulation (EU) No. 575/2013 (CRR) and exposures in default according to Article 112 (j) CRR, broken down by obligors and allocated according to paragraph 55 of Annex II of the ITS on supervisory reporting. In detail, the memorandum rows include the following items:22 row 290: exposures secured by mortgages on commercial immovable property according to Articles 124 and 126 CRR,22 row 300: exposures in default according to Article 112 (j) CRR which are assigned a risk weight of 100%22 row 310: exposures secured by mortgages on residential immovable property according to Articles 124 and 125 CRR22 row 320: exposures in default according to Article 112 (j) CRR which are assigned a risk weight of 150%See answer to Q&A 2014_1163 for the treatment of exposures secured by mortgages on a real estate which are in default. Question 2According to paragraph 53 of Annex II of the ITS on supervisory reporting, the memorandum items in rows 290 to 320 of table C 07.00 must not be reported for the exposure class "exposures associated with particularly high risk".The intent of the respective rows is to 1cprovide additional information about the obligor structure of the exposure classes 'in default' or 'secured by immovable property' 1d (see paragraph 55 of Annex II of the ITS on supervisory reporting). Hence, exposures which are originally assigned to the exposure class "exposures associated with particularly high risk" (Article 112 (k) CRR) must not be included in the memorandum items of rows 290 to 320.
Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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