FINREP Forms F.04.03.1 and F.04.03.2 require the disclosure of partial and total-write offs in columns 080 and 090. Reference is made to IFRS 9.5.4.4 and B5.4.9 and Annex V.Part 2.72-74.Both references are however silent, as to how long the disclosure about in particular total write-offs is required. Is the disclosure of total write-offs only required in the year, when the total-write off has occurred? (Rationale: A (total) write-off constitutes a derecognition event - a disclosure for instruments no longer recognised does not make sense in the following year).Alternative view: Guidance in Part 2.72 is equally valid for partial and total write-offs. This means, the amounts in columns 080 and 090 ‘shall be reported until the total extinguishment of all the reporting institution’s rights by expiry of the statute-of-limitations period, forgiveness or other causes, or until recovery’, i.e. as long as ‘they are subject to enforcement activities’. This would mean, that partial write-offs would NOT be required to be reported, if a certain amount (e.g. 50%) was forgiven and therefore written off and is therefore also no longer enforced. Simultaneously, even total-write-offs would have to be reported, as long as enforcement activities are undertaken, also in later years. This view however seems to be somewhat in contradiction with IFRS 9.B.5.4.9, which stipulates that write-offs should only occur, ‘if the entity has no reasonable prospects of recovering any further cash flows from the financial asset’. Thus, the column would have to be filled in only in the very rare cases, where ‘the entity has no reasonable prospect of recovering any further cash flows from the financial assets’, but still undertakes enforcement activities.Is this interpretation correct?
- Legal act: Regulation (EU) No 575/2013 (CRR)
- COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
