Question ID
2021_6264
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
Annex V
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
Annex V
Type of submitter
Credit institution
Subject matter
Validation rule v6011_h
Question

The validation rule v6011_h checks if the accumulated impairment of loans and advances for non-financial corporations (row 190) is lower than the sum of accumulated impairments of small and medium-sized enterprises (row 200), belonging to non-financial corporations.

In most cases the accumulated impairment is negative.

e.g.:

Impairment = - 40

r190 (Loans and advances NFC) = -40

r200 (of which: SME) = 0

In this case c190 < c200 and the validation rule is not violated.

The question is, how should we deal with positive accumulated impairment due to POCI deals?

e.g.:

Impairment = + 40

r190 (Loans and advances NFC) = +40

r200 (of which: SME) = 0

In this case c190 > c200 and the validation rule is violated, although positive impairment is generally allowed.

Background on the question

Validation rule v6011_h requires the following condition to be fulfilled:

F 20.04 (c031, All sheets), {r190} <= +{r200}

Column 031 in F20.04 refers to accumulated impairment, Row 190 refers to Loans and advances for Non-financial corporations and row 200 refers to of which: small and medium-sized enterprises of the row 190. The biggest change in the DPM3.0 (30.06.2021) was the separate disclosure of POCI deals in different tables. According Annex V Part 2. 70(d) “Accumulated impairment for purchased or originated credit-impaired financial assets can be positive in case of impairment gains exceeding any previously recognised impairment losses”. According to rule v6011_h it’s forbidden to disclosure positive impairment in table F20.04.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the matter it refers to has already been identified and will be considered for a forthcoming version of the Reporting framework and release of the respective validation rules.

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Status
Rejected question