Question ID
2018_3934
Legal act
Directive 2013/36/EU (CRD)
Topic
Supervisory reporting - Supervisory Benchmarking
Article
78
Paragraph
2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
Article/Paragraph
Validation Rules
Type of submitter
Individual
Subject matter
Meaning of current year in validation rule v6167_m
Question

What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

Background on the question

For v2.8 framework version, a new validation rule was added, v6167_m, C 101.00:  {c050} <= 31-Dec-'current year-1'. Please help me with some clarification regarding the current year interpretation in this formula.

From a technical perspective it is a little bit confusing as end of year might be considered reference date of report and this might have a totally different meaning than the current year.

Submission date
Final publishing date
Final answer

Commission Implementing Regulation (EU) 2016/2070 specifies the instructions for the reporting of supervisory benchmarking of internal approaches for calculating own funds requirements, according to article 78(2) of Directive 2013/36/EU. In particular, according to the instructions referred to in Table C 101 of Annex IV, column 050 (“Date of most recent rating of counterparty”) shall contain the date of the most recent rating of the counterparty.

Validation rule v6167_m further specifies that the most recent rating date shall be reported, as long as it falls within the time frame of the benchmarking exercise. For example, let us consider a counterparty that has received a rating on February 2017, October 2017 and February 2018. For the benchmarking exercise of December 2017 the rating that occurred in October 2017 shall be considered, even if there exists a later rating taking place before the actual reporting date.

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.
Note to Q&A
Update 26.03.2021: This Q&A has been reviewed in the light of the most recent amendments to the ITS 2016/2070 on Supervisory Benchmarking and continues to be relevant.

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.