Question ID
2025_7320
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
Annex V
Paragraph
Para 117- Section 19.2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
Article/Paragraph
Annex V, Para 117- Section 19.2
Type of submitter
Credit institution
Subject matter
EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).
Question

a) The “Custody assets” referred in FINREP 22.2 is described as “service of safekeeping & administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”. How the word “Service” in above definition needs to be interpreted? Does it mean to populate balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee is charged /revenue being generated?

21.2. Assets involved in the services provided (22.2)
285. Business related to asset management, custody functions, and other
services provided by the institution shall be reported using the following
definitions:
(a) ‘Asset management’ shall refer to assets belonging directly to the
customers, for which the institution is providing management. ‘Asset
management’ shall be reported by type of customer: collective investment
undertakings, pension funds, customer portfolios managed on a
discretionary basis, and other investment vehicles;
(b) ‘Custody assets’ shall refer to the services of safekeeping and
administration of financial instruments for the account of clients provided
by the institution and services related to custodianship such as cash and
collateral management. ‘Custody assets’ shall be reported by type of
customers for which the institution is holding the assets distinguishing
between collective investment undertakings and others. The item ‘of which:
entrusted to other entities’ shall refer to the amount of assets included in
custody assets for which the institution has given the effective custody to
other entities;

b)    As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSIB is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

Background on the question

" EBA_v10862” validation rule checks assets under custody in GSIB matches back with FINREP 22.02 custody assets. The guidance for assets under custody for GSIB mentions to include all assets that the reporting group holds as a custodian on behalf of customers including those which are also assets under management and Assets under administration (i.e. only include Asset under management & Assets under administration if they meet the definition of Asset under Custody), whereas, the FINREP table 22.2 starts as Assets involved in services provided which is construed as only those Assets needs to be reported for which there is a corresponding income reported in FINREP table 22.01.

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 versions of the respective validation rules.

Status
Rejected question