Question ID
2014_1309
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
99
Paragraph
2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph
Annex V, Part 2.41 (i)
Type of submitter
Competent authority
Subject matter
Definition of "Other collateralized loans" in relation to validation rules between F 05.00 (r100) and F 13.01 (c030, c040)
Question

Do credit institutions in row "of which: other collateralized loans" in the tables F 05.00 and F 07.00 include also loans and advances that are secured by received financial guarantees or other guarantees? Final draft ITS on supervisory requirements in Annex V, Part 2.41 (i) for Tables F 5.00 states: “Other collateralized loans” include loans formally backed by collateral, independently of their loan/collateral ratio (so-called “loan-to-value”), other than “Loans collateralised by immovable property”, “Finance leases” and “Reverse repurchase loans”. This collateral includes pledges of securities, cash, and other collateral."

Background on the question

n/a

Submission date
Final publishing date
Final answer

For template F 05.00 of Annex III and IV of Regulation (EU) No 680/2014 – ITS on Supervisory Reporting of institutions (ITS on reporting), the definition of “other collateralized loans” in paragraph 41(i) of Part 2 of Annex V of the ITS on reporting is applicable. According to it, the institution shall report loans when they are formally backed by collateral and shall not report the part of collateralized loans which is reported in another place and which belongs to one of the categories “Loans collateralised by immovable property”, “Finance leases” and “Reverse repurchase loans”. At this stage, it can be anticipated that financial guarantees, as defined in paragraph 58 of Part 2 of the Annex V of the ITS on reporting do not comply with the definition of “other collateralized loans”.

The definition provided in Annex V, Part 2, paragraph 41(i) is also applicable for template F 13.01, demonstrating that they should be a consistent population.

In template F 13.01, loans and advances are to be broken down by mortgage loans, other collateralized loans and financial guarantees, as per the definitions in paragraph 81 of Part 2 of Annex V of the ITS on reporting. In table 13, financial guarantees are explicitly excluded from the concept “other collateralized loans”. Since both definitions provided for templates 5 and 13 are aligned by para 41(i), it can be understood that financial guarantees are not to be included in category “other collateralized loans” in template F 05.00.

This is furthermore demonstrated by the validation rule v1076_m (which will be amended and reactivated due to EBA Q&A 2014_1141). This requires the sum of F 05.00, row 100 ("of which: other collateralized loans") to be equal to or more than the sum of F 13.01, row 010, column 030 to column 040 ("other collateralised loans"). This excludes financial guarantees received reported in F 13.01, c050.

As far as template F 07.00 is concerned, it applies the same presentation of loans and advances including the information about collateral as template F 05.00. Therefore, the same instructions in this regard as for template F 05.00 shall apply.

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

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