Question ID
2022_6629
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
430
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Article/Paragraph
Annex V.Part 2.48i
Type of submitter
Individual
Subject matter
Liability for contribution to resolution funds and deposit guarantee schemes in the form of a payment commitment
Question

Paragraph 48i of Part 2 of Annex V to Regulation (EU) 2021/451 states: '[...] Where the contribution [to resolution funds and deposit guarantee schemes] is made in the form of a payment commitment, this payment commitment shall be included in ‘provisions or (-) reversal of provisions’, if the payment commitment gives rise to a liability in accordance with the applicable accounting standard'.

It is not clear in which row of template F 01.02 should be accounted the liability. Row '0230. Other provisions' seems the best choice, but row '0220. Commitments and guarantees given' could be another choice.

Background on the question

From the FinRep's instructions is not clear how to account the liability in counterpart of the expense related to "payment commitments to resolution funds and deposit guarantee schemes".

F 02.00 r0435 - Payment commitments to resolution funds and deposit guarantee schemes       100 - Debit (DARE)
??? F 01.02 r0230 - Other provisions  OR  F 01.02 r0220 - Commitments and guarantees given           100 - Credit (AVERE)
 

IFRIC 21 could be applay if the contribution is trated like a levy. In this view row 230 seems the more appropriate. Furthermore for cell {F 01.02, r0230, c0010} in the EBA DPM, the "Main category that generates the provision (MCP:MC)" consists of provisions "Other than Employee benefits, Restructuring, Pending legal issues and tax litigation, Off-balance sheet exposures subject to credit risk (MC:x893)".

On the other hand, if the contribution is trated like a "commitment to pay" row 220 could also be possible. In this case is not clear which columns of template F 09.01.1 should be filled (probably colomuns 0100 e 0110). However for cell {F 01.02, r0220, c0010} in the EBA DPM the "Main category that generates the provision (MCP:MC)" consists of provisions from "Off-balance sheet exposures subject to credit risk (MC:x251)". In consideration that "contributions to resolution funds and deposit guarantee schemes" are not subject to credit risk, row 220 does not seem to be the right one.

Submission date
Final publishing date
Final answer

A payment commitment to resolution funds and deposit guarantee schemes is a liability which is within the scope of IAS 37 and it is a commitments given, not subject to credit risk.

Since this type of payment commitment is not subject to credit risk, it shall be reported in row 0230 “Other provisions”, rather than in row 0220 of template F 01.02.

Indeed, the row 0220 of template F 01.02 is broken-down in templates F 09, as specified in the column ‘Breakdown in table’ of template F 01.02. In templates F 09, according to paragraph 102 in Part 2 of Annex V to Regulation (EU) 2021/451, the off-balance sheet items listed in Annex I to CRR shall be reported. These off-balance sheet items are those subject to credit risk, as also specified in DPM.

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

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