Question ID
2014_1671
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - Asset Encumbrance
Article
100
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex XVI
Type of submitter
Competent authority
Subject matter
Inconsistent validation rules of asset encumbrance templates (F 32.01, F 32.04, F 36.01)
Question

There are several validation rules that do not appear to be appropriate:

  1. v2823_m
    sum({F 32.01, r120, (c010, c060)}) = sum({F 01.01, c010, (r020, r060, r092, r240-260, r290, r320-330, r360-370)})
    According to the instructions of F 32.01 and validation rule v2814_m, if the asset encumbrance reporting is based on IFRS, then the total assets of the reporting institution (sum({F 32.01,r010,(c010,c060)})) equals to the total assets reported in {F.01.01,r380,c010}.
    In order to meet this requirement, v2823_m should also contain row280 and row310 of F01.01. Now these items are missing from the formula.
  2. Validation rules v2864_m and v2865_m are applicable for rows 020, 030, 050-060 of F 32.04, however row 060 is grey shadowed.
  3. In our understanding v3309_i should be applicable only for IFRS banks because {F 36.01, r230, c180} equals to sum({F 32.01, r010,(c010, c060)}) which equals to Total assets of F 01.01 only if the report is based on IFRS. Now the formula doesn’t distinguish between IFRS and non-IFRS banks.
Background on the question

We have been analysing the validation rules of asset encumbrance templates published on EBA’s website. There seem to be some inconsistencies.

Submission date
Final publishing date
Final answer

Question 1

Validation rule v2823_m aims to check that assets other than equity and debt instruments are equal in template F 32.01 (Asset Encumbrance) of Annex XVI to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting) and in template F 01.01 (FINREP) of Annexes III and IV to the ITS on Supervisory Reporting.

The validation rule does not work because ‘Property, Plant and Equity’ and ‘Goodwill’ as reported in F 01.01 are not included in the formula (but they should be because they are neither debt nor equity instruments). The validation rule will be adapted accordingly.

Question 2

The scope of validation rules v2864_m and v2865_m has been amended. They will not apply anymore to row 060 of template F 32.04 of Annex XVI to the ITS on Supervisory Reporting with effect of end of June 2017.

Question 3

v3309_i verifies that the total assets reported in template F 36.01 of Annex XVI and template F 01.01 of Annexes III and IV to the ITS on Supervisory Reporting are equal. This validation rule holds in any case, considering the fact that the instructions on c180 of F 36.01 of Annex XVI (via the reference to row 010 of F 32.01) require the ‘Total assets of the reporting institution registered in its balance sheet’ to be reported.

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

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