According to Final Q&A 2014_1141, ‘the amounts to be reported in templates F 05.00 and F 13.01 can be different. In the former, the carrying amount of loans shall be reported, while in the latter the amount of the collateral shall be reported, capped by the amount of the loan.’

Also according to the Final Q&A 2014_1309, ‘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.’

According to Final Q&A 2013_685, if loans and advances are simultaneously secured by more than one type of collateral, for example secured by immovable property and other collateral, then: ‘F 05.00 Template requires a breakdown of loans and advances both by product and by type of counterparty. In this template, the entire amount of a given loan contract should be reported in the corresponding type (or types) of loans and advances and not been distributed among various types. The instructions for classifying loan contracts between the two types of collateralized loans (mortgage loans and other collateralized loans) say that mortgages loans include loans formally secured by immovable property independently of the loan/collateral ratio (Annex V. Part 2. Paragraph 41.(h) of the draft ITS on Supervisory reporting). Therefore, the entire amount of the contract should be reported in mortgage loans regardless whether the loan is over-collateralized, under-collateralized or the real estate collateral is complemented by other collateral. The purpose of F 05.00 Template is to collect the amount of all contracts that are formally mortgages.
(…) The instructions for F 13.01 Template explicitly contemplate the case of loans with simultaneously more than one type of collateral and indicate that the allocation amount of the various types should be based on the quality of the collateral (Annex V. Part 2. Paragraph 82 of the draft ITS on Supervisory reporting). (…)’.

It is our view that Q&A 2013_685 contradicts with Q&A 2014_1309.
According to the Q&A 2013_685, in the case where a loan is fully collateralized by part cash and part immovable property collateral, then in template F 13.01 the cash collateral (more liquid therefore of higher quality) will firstly be used / reported to secure the loan and afterwards the property collateral will be used / reported for collateralizing the remaining amount of the loan. Whereas in template3 F 05.00 the entire amount of the loan would be reported in row ‘Mortgage loans (loans collateralized by immovable property)’ due to the fact that the loan has property collateral.
However, in this case the loan will not be reported in F 05.00, row ‘Other collateralized loans’, because it is already reported in F 05.00 as a loan collateralized by immovable property (i.e. mortgage) and as per Annex V instructions Part 2, chapter 5, paragraph 41 (i) ‘’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’ […]’. Consequently, row ‘other collateralized loans’ of template F 05.00 will be less than ‘other collateralized loans’ of template F 13.01 (F 05.00 < F13.01) because the amount of the loan will NOT be reported in F 05.00 row ‘other collateralized loans’, whereas the amount of cash used will be reported in F 13.01, ‘other collateralized loans’.

We believe that based on the above example, the below validation rules cannot be true to all cases and should be deactivated:

v1076_m: sum({F 13.01, r010, (c030-040)}) <= sum({F 05.00, r100, (c020-060)})

v1079_m: sum({F 13.01, r020, (c030-040)}) <= {F 05.00, r100, c040}

v1082_m: sum({F 13.01, r030, (c030-040)}) <= {F 05.00, r100, c050}

v1085_m: sum({F 13.01, r040, (c030-040)}) <= {F 05.00, r100, c060}