Question ID
2018_3670
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
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Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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
columns c011, c012, c022 and c025 of table F 20.04
Name of institution / submitter
Austrian Economic Chamber, Division Bank and Insurance
Country of incorporation / residence
Austria
Type of submitter
Industry association
Subject matter
Discrepancies between annotated table layout and EBA validation rules (e.g. v5351_m)
Question

1) Are the columns 011, 012, 022 and 025 of template F 20.04 in the annotated table layout (FN1) not intended to be subsets of column 010, meaning that a limitation on ‘other than held for sale’ in column 010 would indicate the same limitation for the ’of-which’ columns?

2) If there is a limitation on ’other than held for sale’ in template F 20.04, column 010, does this limitation not contradict the above mentioned validation rule v5351_m, if the same limitation is not indicated in template F 06.01? The same problem occurs for validation rules v5350_m, v5353_m, v5725_m, v6054_m, v6055_m, v6056_m, v6057_m, v6058_m and v6059_m (FN2).

Foot notes:

  • FN 1: DPM table layout and data point categorisation updated 27 April 2017
  • FN 2: Validation rules updated 08 December 2017

 

Background on the question

The annotated table layout indicates a limitation on “other than held for sale” for table F20.04, column c010. For the “of-which”-columns c011, c012, c022 and c025 this limitation is not intended. Due to this limitation in column c010, several discrepancies with the validation rules occur. For example, validation rule v5351_m ({F 06.01, r190, c010} = sum({F 20.04, r190, c010, (sNNN)}) - sum({F 20.04, r190, c011, (sNNN)})) refers to this column. In table F 06.01, however, no held-for-sale limitation is intended.

Submission date
Final publishing date
Final answer

In accordance with Part 1, paragraph 13 of Annex V to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), ‘accounting portfolios’ shall exclude, among others, financial instruments classified as ’Held for sale’ presented in the items ‘Non-current assets and disposal groups classified as held for sale’.

Template F 06.01 of Annexes III and IV to the ITS on Supervisory Reporting presents detailed information on accounting portfolios other than ‘held for trading’ or ‘trading assets’ and thus excludes held for sale items as well. This is, however, only indirectly reflected in the DPM; for example, a comparison between hierarchies PL38 (hierarchy for Financial assets other than Held for trading and Trading Financial Assets) and PL39 (Hierarchy for Accounting portfolios for financial assets other than classified as held for sale) shows that PL38 is a subset of PL39, and consequently, that PL:x77 (‘Financial assets other than Held for trading and Trading Financial Assets’ as the member used in the modelling of F 06.01) should exclude held for sale items as well. Analogous considerations apply for template F 05.01.

With regard to the questions raised:

  1. Columns 011, 012, 022 and 025 are a subset of column 010 of template F 20.04 and all exclude items classified as ‘held for sale’.
  2. Validation rules v5350_m, v5351_m, v5353_m, v5725_m, v6054_m, v6055_m, v6056_m, v6057_m, v6058_m and v6059_m are consistent and correct in terms of exclusion of items classified as held for sale.

 

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

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