Question ID
2024_7153
Legal act
Directive 2014/59/EU (BRRD)
Topic
BRRD Reporting
Article
Article 45i
Paragraph
Paragraph 1
Subparagraph
letter (a,c)
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
Article/Paragraph
3456 and the annexes cross referred there in
Type of submitter
Credit institution
Subject matter
MREL-REPORTING OF THE IMPACT OF GENERAL PRIOR PERMISSION
Question

With reference to the Q&A 6852, we kindly request clarification on the appropriate logic to utilize when adding the amounts of the unused portion of the GPP for the rows in Template M 01.00, specifically rows 0250 to 0290.

We would greatly appreciate if you could provide guidance on the correct allocation of the unused amount for rows 0260, 0270, 0280, 0285, and 0290. Given that the GPP has a duration of one year, it is our understanding that the unused amount should be accounted for solely in rows 0250 and 0285, as per convention.

Background on the question

The Q&A 2023_6852 does not provide a clarification on this specific point. 

Submission date
Final publishing date
Final answer

In accordance with the instructions for row 0250-0290 of template M 01.00 of Annex I to Regulation (EU) 2021/763 (ITS on disclosures and reporting on MREL and TLAC), provided in Annex II thereto, unused general prior permission amounts shall be included in the rows dedicated to other bail-in-able liabilities, to the extent that those permissions refer to eligible liabilities instruments (i.e. prior permissions covering own funds instruments are not to be reported there).

This means the following for the unused general prior permission amounts covering eligible liabilities instruments:

  • Unused general prior permission amounts should be reported in the 'total'-row for other bail-inable liabilities (row 0250).

As a convention, unused general prior permission amounts should be reported in row 0280 ('Residual maturity of < 1 year') of the maturity breakdown.

Status
Final Q&A

Disclaimer

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