Question ID
2025_7301
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
Annex V Part 1.44(h) & Part 2.102-103, 115
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
Article/Paragraph
Annex V Part 1.44(h) & Part 2.102-103, 115
Type of submitter
Other
Subject matter
Other commitments received - calculation of guarantee amounts
Question

On report F09.02, banks are asked to report guarantees received as collateral, partly in column 0010 and partly in column 0020. Where some questions have been answered in earlier Q&As, some questions remain:

Based on Q&A 2013_214, guarantees received on off-balance sheet exposures should be reported as "Other Commitments Received". These are reported in F09.02 Col0020.
Based on Q&A 2023_6773, in F09.02 Col0010, guarantees are considered by ignoring other collaterals.

Should other collaterals be considered in calculating the amount reported in column 0020?

Along the same lines, how should calculations work for both columns 0010 and 0020 if multiple guarantees are received? Within the same group of exposures and its/their contractually linked collaterals/guarantees, should they all be calculated separately and independently, ignoring the existence of other guarantees within the same group similar to the way other collaterals in the same group are ignored?

The ITS states that "For other commitments received, the nominal amount shall be the total amount committed by the other party in the transaction." is to be reported in column 0020.  Does this also apply in the case whereby a guarantee is received to secure an (off-balance) exposures? In other words, should it be capped at the Off-Balance Exposure Amount or not?

Background on the question

This section contains or may contain guaranteed received with the intent to secure an exposure that is not (yet) on the balance sheet. We wonder if there should be a different treatment for guarantees received to secure an on-balance sheet exposure versus guarantees received to secure an off-balance sheet exposure.

Submission date
Final publishing date
Final answer

Following the provisions included in Commission Implementing Regulation (EU) 2021/451, Annex V, Part 2, paragraph 119 and the clarifications given in the Q&As 2013_214, guarantees received on 'off-balance sheet exposures' should be treated as 'other commitment received'. Therefore, their nominal amount should be the total amount committed by the other party in the transaction, as specified in paragraph 119 mentioned above. 

Furthermore, following the clarifications given in Q&As 2023_6773, other collaterals should not be considered for the purpose of reporting financial guarantees in template F 09.02. The same approach should be implicitly applied for reporting other commitments in template F 09.02, in case of the existence of other collaterals. 

Eventually, in case of multiple guarantees, the provisions in paragraph 119 should be met: '[...] Where a financial guarantee received has been issued by more than one guarantor, the guaranteed amount shall be reported only once in this template; the guaranteed amount shall be allocated to guarantor that is more relevant for the mitigation of credit risk'.

Status
Final Q&A

Disclaimer

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