Question ID
2017_3201
Legal act
Directive 2013/36/EU (CRD)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
78
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
Article/Paragraph
Annex I, C 102.00
Type of submitter
Industry association
Subject matter
Definition of low default portfolios for 2017 supervisory benchmarking exercise: Missing Portfolio ID for exposures assigned to both the exposure class ‘institutions’ and to the sector of counterparty ‘general governments’
Question

Which Portfolio ID should be used regarding the definition of low default portfolios (Annex I, C 102.00 Draft ITS) for exposures assigned to both
(i) the exposure class ‘institutions’ in accordance with annex II, C 102.00, column 070 Draft ITS with reference to COREP and
(ii) the sector of counterparty ‘general governments’ in accordance with annex II, C 102.00, column 080 Draft ITS with reference to FINREP?

Background on the question

Annex I of the Draft ITS on Supervisory Reporting for Institutions (for benchmarking the internal approaches) submitted to the European Commission on 4 August 2016 defines the supervisory benchmarking portfolios of the 2017 EU supervisory benchmarking exercise.

Regarding the definition of low default portfolios (Annex I, C 102.00 Draft ITS) there are no portfolios defined that could be used for exposures that are assigned to both the exposure class ‘institutions’ and the sector of counterparty ‘general governments’.

Regarding the assignment of the exposure class Annex II, C 102.00, column 070 Draft ITS refers to paragraph 78 of annex II of Commission Implementing Regulation (EU) No 680/2014 (COREP). Commission Implementing Regulation (EU) 2016/1702 amends Commission Implementing Regulation (EU) No 680/2014. Annex II, Part II, paragraph 77 of Commission Implementing Regulation (EU) 2016/1702 refers to article 147 CRR. In accordance with Article 147 (4) a CRR exposures to regional governments and local authorities which are not treated as exposures to central governments shall be assigned to the exposure class ‘exposures to institutions’. Regarding the assignment of the sector of counterparty annex II, C 102, column 080 Draft ITS refers to FINREP-based economic sector classes. In accordance with Annex V part 1 paragraph 35 of Commission Implementing Regulation (EU) 2016/1702 state or regional governments and local governments shall be assigned to the counterparty sector ‘general governments’.

Submission date
Final publishing date
Final answer

It is correct that separate portfolios for the combination of the exposure class ‘institutions’ and the sector of counterparty ‘general governments’, thus exposures covered by Article 147 (4) lit. a of Regulation (EU) No 575/2013 (CRR), are missing in Annex I to the Draft ITS on Supervisory Reporting for Institutions for benchmarking the internal approaches (ITS on Supervisory Benchmarking) for the 2017-benchmarking exercise (end-2016 data). Thus, those exposures do not have to be reported.

Disclaimer

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

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

Disclaimer

The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.