Consultation Paper On The ITS On Supervisory Reporting
Consultation Paper On The ITS On Supervisory Reporting
Consultation Paper On The ITS On Supervisory Reporting
16 October 2019
Consultation Paper
Contents
1. Responding to this consultation 3
2. Executive Summary 4
3. Background and rationale 6
3.1 New banking regulatory package 6
3.2 Regulation on minimum coverage of non-performing exposures 7
3.3 Integration of Pillar 3 disclosure requirements into supervisory reporting 7
3.4 Proportionality in reporting requirements 8
3.5 Reporting changes topic by topic 9
3.5.1 Own funds 9
3.5.2 NPL backstop 9
3.5.3 Credit risk 11
3.5.4 Counterparty credit risk 13
3.5.5 Leverage ratio 15
3.5.6 Large Exposures 17
3.5.7 NSFR 18
3.5.8 Other amendments 19
3.6 Changes to the reporting framework and implementation timelines 20
4. Draft regulatory implementing standards 22
5. Accompanying documents 43
5.1 Additional clarifying examples 43
5.1.1 NPL backstop 43
5.1.2 Leverage ratio – Public Development and Promotional Activities – Structure
Examples 45
5.1.3 NSFR 49
5.2 “NSFR calculation tool” 50
5.3 Draft cost-benefit analysis / impact assessment 50
5.4 Overview of questions for consultation 63
5.4.1 Own funds 63
5.4.2 NPL backstop 64
5.4.3 Credit risk 64
5.4.4 Counterparty credit risk 65
5.4.5 Leverage ratio 65
5.4.6 Large Exposures 66
5.4.7 NSFR 67
5.4.8 FINREP 67
5.4.9 Other amendments 69
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Submission of responses
To submit your comments, click on the ‘send your comments’ button on the consultation page
by 16.01.2020. Please note that comments submitted after this deadline, or submitted via other
means may not be processed.
Publication of responses
Please clearly indicate in the consultation form if you wish your comments to be disclosed or to
be treated as confidential. A confidential response may be requested from us in accordance with
the EBA’s rules on public access to documents. We may consult you if we receive such a request.
Any decision we make not to disclose the response is reviewable by the EBA’s Board of Appeal
and the European Ombudsman.
Data protection
The protection of individuals with regard to the processing of personal data by the EBA is based
on Regulation (EC) N° 45/2001 of the European Parliament and of the Council of 18 December
2000 as implemented by the EBA in its implementing rules adopted by its Management Board.
Further information on data protection can be found under the Legal notice section of the EBA
website.
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2. Executive Summary
Regulation (EU) No 575/2013 (‘the CRR’) mandates the EBA, in Article 430(7), to develop uniform
reporting requirements. These reporting requirements are included in the proposed
Implementing Technical Standards. These standards cover information on institutions’
compliance with prudential requirements as put forward by the CRR and related technical
standards as well as additional financial information required by supervisors to perform their
supervisory tasks. As such, the ITS on supervisory reporting need to be updated whenever
prudential or supervisory requirements change.
In 2019 there were two amendments to the CRR affecting supervisory reporting:
The amending Regulation (EU) 2019/876 (‘CRR2’), which implements a number of key measures
in the EU for institutions, covering many different topics such as liquidity, leverage and large
exposures.
The amending Regulation (EU) 2019/630 (‘Backstop Regulation’), which sets out uniform
minimum levels of coverage to ensure that institutions have sufficient loss coverage for future
non-performing exposures (NPEs).
In order to be in line with those amendments, a number of reporting modules had to be revised.
Integration of disclosures
There are commonalities of the information that institutions have to report to their supervisors and
the regulatory information that they have to make public in the interest of investors and external
stakeholders. Therefore, consistency and integration between both frameworks should be targeted
to the extent possible. To ensure consistency, an integration between supervisory reporting and
disclosures was carried out throughout the whole review of reporting and disclosure requirements.
This consultation paper proposes a new ITS on supervisory reporting which will cover all
supervisory reporting requirements for institutions under CRR. This ITS will replace the
Commission Implementing Regulation (EU) No 680/2014.
Next steps
After a consultation period of 3 months the EBA will deliver the final draft ITS to the EU Commission
in order for the implementation date of the supervisory reporting to be aligned with the application
of the CRR2 requirements.
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The EBA’s submission of the final updated ITS to the EU Commission is expected to take place in
June 2020.The EBA will also develop the data-point model (DPM), XBRL taxonomy and validation
rules based on the final draft ITS. The first reference date for the application of these technical
standards is foreseen to be on 30 June 2021. The expected implementation period for the proposed
changes is approximately 1 year.
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2. The Single Rulebook aims at providing a single set of harmonised prudential rules for financial
institutions throughout the EU, helping create a level playing field and providing high protection to
depositors, investors and consumers. These draft Implementing Technical Standards (ITS) reflect
the single rulebook at the reporting level. These draft ITS form part of this single rulebook for
banking in Europe and become directly applicable in all Member States once adopted by the
European Commission and published in the Official Journal of the EU.
3. Regulation (EU) No 575/2013 (‘the CRR’) mandates the EBA, in Article 430(7), to develop uniform
reporting requirements. These reporting requirements are included in the proposed Implementing
Technical Standards. These standards cover information on institutions’ compliance with prudential
requirements as put forward by the CRR and related technical standards as well as additional
financial information required by supervisors to perform their supervisory tasks. Hence, the ITS on
supervisory reporting needs to be updated whenever the underlying legal requirements change or
it is necessary to improve the supervisors’ ability to monitor and assess institutions.
5. The CRR2 includes a number of key measures, such as amendments regarding the leverage ratio,
the new net stable funding requirement, a new market risk framework introduced in form of a
reporting requirement or a new total loss absorbing capacity (TLAC) requirement. Besides these
changes to the substance of the prudential framework, the reporting and disclosure requirements
themselves have been subject to amendments.
6. The package also aims to enhance proportionality, as the rules are more growth-friendly and better
adapted to the size, risk and systemic importance of the institutions. Proportionality is also
reflected in the EBA proposals for reporting requirements. Proportionality and other means to
address reporting costs will also be discussed in the context of the cost of compliance study on
1
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019L0878&from=EN
2
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R0876&from=EN
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reporting and the feasibility study on integrated reporting that the EBA is
mandated to submit to the Commission by the CRR2.
8. Following this request, the Regulation (EU) 2019/630 amending Regulation (EU) No 575/2013
(‘Backstop Regulation’)3 was published in April 2019. It introduced a Pillar 1 measure that directly
applies to all institutions subject to the CRR. In particular, the Backstop Regulation sets out uniform
minimum levels of coverage to ensure that institutions have sufficient loss coverage for newly
originated exposures that turn non-performing .
10.The information included in the reporting framework is the basis for supervisors and resolution
authorities to form a clear picture on the situation of an institution in terms of business
model/profitability, solvency/risk profile, liquidity and relevance for the financial system and
resolvability. Similarly, the information disclosed by institutions is the basis for market participants
to understand and assess the institutions’ situation in order to exercise market discipline.
Information relevant for market participants is also relevant to help supervisors on their tasks
thereby emphasizing the importance of striving for congruency.
11.Improving the consistency between the reporting and disclosure requirements, including a
standardisation of formats and definitions, should also facilitate the compliance with both
requirements for institutions, as they would use the same data to fulfill their reporting and
disclosure obligations. Further, the integration with supervisory reporting will improve the quality
of the disclosed information since the former is subject to scrutiny by the supervisor, which due to
the mapping of reporting data with disclosures, will also improve the disclosure data and therefore
beneficiate all market participants to take more informed decisions.
3
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R0630&from=IT
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CONSULTATION PAPER ON DRAFT ITS ON SUPERVISORY REPORTING
12.The abovementioned integration between supervisory reporting and disclosures is carried out
through this consultation paper and the consultation paper on the draft ITS on institutions’ public
disclosure. The consultation on that draft ITS applicable to all institutions subject to the disclosure
requirements under Part Eight of the CRR will be running at the same time as this consultation on
the reporting requirements. In the context of consultation on the draft ITS on public disclosures,
the EBA is publishing a mapping between the disclosures and the reporting templates to
demonstrate how the frameworks have been integrated.
14.Many elements of proportionality in supervisory reporting are implicit as they are driven by the
regulatory regime, prudential approaches or by the business model of an institution. For example,
the scope of data to be submitted depends on factors such as whether internal models for the
calculation of own funds requirements are used or if institutions have issued covered bonds or
securitisations.
15.The supervisory reporting framework also incorporates different, tailored reporting frequencies
and includes defined size and risk-specific criteria and thresholds to trigger certain reporting
requirements (e.g. for reporting on sovereign exposures, large exposures, geographical
breakdowns, details of non-performing exposures), in order to take into account the nature,
complexity and riskiness of institutions’ activities.
16.The CRR2 introduces definitions for ‘small and non-complex institutions’ and ‘large institutions’
for enhanced proportionality. The EBA has reviewed all criteria and thresholds on size and
complexity used in the reporting framework with the aim to streamline them, referring to the CRR
definitions for small and non-complex institutions and large institutions where suitable. These CRR
categories are used across the reporting framework to exempt, for example, small and non-complex
institutions from some reporting requirements or, in case of large institutions, to trigger additional
reporting requirements.
a. The design and the content of the new COREP templates on prudential backstop
reflect the minimum level of information necessary for the calculation of minimum
loss coverage and CET1 deductions for NPEs as well as for the monitoring of the
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b. Requirement of some of the newly implemented IRB and CCR templates only for large
institutions or large institutions which are either G-SIIs or listed. Most of these
templates also include a reduced frequency (semi-annually/annually);
18.The proposed amendment to the reporting on own funds and the capital adequacy templates are
driven by the changes to the own funds framework introduced by the CRR2 and the integration of
own funds reporting and own funds disclosure.
19.The CRR2-related changes include, among others, new items reflecting the additional deductions
to be made from own funds, such as the deduction for the insufficient coverage for non-performing
exposures, and items covering the effect of both the final and transitional provisions on the revised
eligibility criteria (C 01.00, C 05.01). At a later stage, the reporting requirements may be reviewed
to reflect policies still to be developed by the EBA, such as the RTS on the application of the
deductions of prudently valued software assets on the basis of Article 36 (4) CRR.
20.In the context of the integration with disclosure, a limited number of breakdowns and
memorandum items, such as information on the surplus or deficit of CET1 considering the
combination of Pillar 1 and Pillar 2 requirements, has been added to templates C 01.00 to C 04.00.
21.Apart from this, templates C 04.00 and C 05.01 have been streamlined by eliminating the
information on the Basel I floor and the transitional provisions which have already expired.
22.Following the Backstop Regulation, the EBA has developed three templates under its Common
Reporting (COREP) framework, as explained below.
23.Similarly, the EBA has also extended the financial reporting for NPEs in line with the structure of
the amendments to COREP. This allows supervisors to monitor the calculation of the specific credit
risk adjustments that are based on the accumulated impairment recognised under the applicable
accounting framework and constitute an important part of the backstop calculation of the minimum
loss coverage under the CRR.
Proposal on the new templates for the calculation of minimum loss coverage requirements
and CET1 deductions under CRR
24.The proposal under COREP framework includes a set of three templates on NPE loss coverage (NPE
LC).
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26.Template C 35.01 - the calculation of deductions for non-performing exposures (NPE LC1): the
templates presents high-level calculation of:
d. total provisions and adjustments or deductions (capped) which are capped to the level
of total minimum coverage requirement for non-performing exposures, and
27.In the template, the columns indicate the time buckets defined as years passed since exposures
have been classified as non-performing. Each time buckets corresponds to a specific coverage
factor.
28.In the accompanying documents section 5.1.1 there is a box which presents the formula and the
steps for the calculation of minimum coverage requirement and the applicable amount of
insufficient coverage.
30.The template requires institutions to report under each time buckets minimum coverage
requirement for unsecured and secured non-performing, not forborne exposures given the
exposure value and the factors defined in Article 47c(2) of the CRR.
31.The template makes the distinction between the type of security and indicates the factors in
accordance with Article 47c(2) of the CRR.
33.The template requires institutions to report under each time buckets minimum coverage
requirement for unsecured and secured non-performing, forborne exposures given the exposure
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value and the factors defined in Article 47c(2) of the CRR and in accordance
with the forbearance requirements specified in Article 47c(6) of the CRR.
34.The definition of the definition of NPEs and Forbearance has been removed from FINREP
instructions, given that it is now included in the CRR itself. Furthermore, the EBA is proposing to
introduce a new template (F39) in FINREP for reporting NPEs by time buckets with a semi-annual
frequency. In the new template, the gross carrying amount/nominal value of NPEs and the related
loss allowances/provisions have been broken by the same time buckets as introduced in Article 47c
of the CRR and used in the new NPE LC templates of COREP as well. The NPEs have been also broken-
down by instrument and some additional details (e.g. the amount of exposures affected by the
Backstop Regulation) are provided in separate rows. This amendment facilitates banks to determine
the appropriate amounts of specific credit risk adjustments to be included in the backstop
calculation. Furthermore, it enhances supervisors’ ability to monitor the accuracy of a bank’s
specific credit risk adjustments calculation.
35.While the new templates in COREP have been introduced to calculate the NPE loss coverage and
capital requirements within the framework of CRR Pillar 1 measures, the new FINREP template aims
to monitor the stock of NPEs and the related loss coverage from an accounting perspective.
36.The EBA is of the view that the financial reporting of NPEs broken-down by time buckets
complements, from an accounting point of view, the information included in the new Corep
templates on NPE loss coverage. In particular, the new Finrep template allows supervisors to
conduct reviews, as part of their SREP process, on the accounting impairment coverage levels that
are the basis for determining the specific credit risk adjustments included in the backstop
calculation.
37. In reviewing the specific credit risk adjustments, it should be noted that accounting impairment
coverage differences may warrant specific supervisory attention, in order to assess any (additional)
capital requirement under the SREP process. Firstly, Article 47c of the CRR does not require
institutions to hold a minimum level of loss coverage for NPEs in the first two years following
classification as non-performing. Secondly, current loss coverages varies across institutions from
approximately 25% to 60% of the amount of exposures in each time bucket. It is therefore essential
to oversee the institutions’ NPE impairments within these time buckets and to assess any variations
in impairments for similar portfolios and in similar time buckets.
38.Indeed, as the institutions are now required to calculate minimum level of loss coverage for NPEs
under the CRR, it becomes more relevant to compare the time breakdown in FINREP in the same
fashion, i.e. in the same calendar design, yet acknowledging key conceptual differences between
them, e.g. differences in definitions such as exposure value vs. gross carrying amount. In all cases,
the new data requirements should by no means be interpreted as an EBA expectation that the
minimum level of loss coverage for NPEs under the CRR have to be reflected in the calculation of
accounting credit losses.
CRR2 alignment
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39.One of the key elements of the CRR2 is to make it easier for institutions to lend
to Small and Medium-sized Enterprises (SMEs) and fund infrastructure
projects to support investment. To that end the CRR2 introduces provisions to reduce the own
funds requirements for exposures to infrastructure projects and to extend the scope of the
exposures subject to the existing reduction in own funds requirements for SMEs. This has been
reflected in supervisory reporting accordingly to capture RWEAs reduction related to exposures to
infrastructure projects, both in SA and IRB templates.
40.The CRR2 amends the Collective Investment Units (‘CIUs’) framework to be in line with the revised
capital requirements for institutions’ equity investments in funds issued by Basel Committee of
Banking Supervisors (BCBS) (published December 2013). In the CRR2 there are 5 new articles on the
CIUs framework regarding items associated with high risk (which in CRR2 excludes CIUs). The
revised provisions introduce new calculation methods of the capital requirements for this specific
type of exposures in both the look-through approach and the mandate-based approach and
introduced a new approach – the fall-back approach (RW of 1250%). Moreover, a combination of
these approaches can be used, subject to fulfillment of conditions for the application of each of the
approaches. The revised SA templates enable the analysis of this new framework and provide more
detail on the different approaches used. In order to convey that, additional rows on the three
possible approaches (Look-through, Mandate-based and Fall-back approaches) plus the deductions
due to exposures to CIUs were added in C 07.00 and C 09.01.
Disclosures alignment
41.The commitment to align the disclosure requirements with supervisory reporting to the extent
possible means that all information disclosed by institutions shall be conveyed by supervisory
reporting as well. The new templates introduced ensure enhanced comparability between
institutions both by supervisors and by the general public. These templates are:
a. C08.03 that provides all relevant parameters used for the calculation of credit risk
capital requirements for IRB models;
b. C08.04 that presents a flow statement explaining changes in credit risk RWAs
determined under the IRB approach for credit risk;
c. C 08.05 and C 08.05b4 that provide information on the results of backtesting of PDs for
the models reported;
d. C 08.06 that provides all relevant parameters used for the calculation of credit risk
capital requirements under the slotting criteria for specialized lending;
42.This data on supervisory reporting will be subject to validation rules, DPM and taxonomy, as any
other reporting template. Therefore, there will be a better understanding about what exactly is the
data being disclosed as well. Moreover, these reporting templates will be subject to data quality
checks by the supervisors, which, due to the integration with disclosures, will also improve the
4
The inclusion of C 08.05b will depend on the feedback received from the Consultation Paper on disclosures
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disclosure data and therefore allow the general users of information to take
more informed decisions.
43.In order to minimize the reporting cost for institutions, it is proposed that the new templates
introduced are aligned with disclosures in terms of the scope of institutions which have to report
them, and also in terms of frequency. Therefore, only institutions which are subject to these
disclosure requirements have to report the new templates with the same frequency. In line with
this, all the new proposed templates will have reduced frequencies, except for C 08.04 for G-SIIs
and listed institutions, which shall be quarterly reported. No further information has to be collected
or calculated by institutions when implementing these new reporting templates.
Further amendments
44.In February 2016 the EBA set out a roadmap for the implementation of the regulatory review of
the IRB approach5, with three main areas outlined to repair and restore trust of IRB models:
review of the regulatory framework
45.Following the completion of Basel III reforms, a new comprehensive revision of the CRR (CRR3) is
expected, which will affect the whole credit risk framework substantially. Upon the publication of
this regulatory package, new changes will be needed for supervisory reporting concerning as well.
46.The CRR2 has revised the counterparty credit risk framework following the Basel III reforms6, and
therefore replaces the Standardised Method (SM), the Mark-to-Market Method (MtMM) with the
Standardised Approach for Counterparty Credit Risk (SA-CCR). The SA-CCR is more risk sensitive but
may prove to be too complex and costly to implement for smaller institutions. For this reason the
CRR2 also includes a simplified version of the SA-CCR (the ‘simplified SA-CCR’) and an updated
version of the Original Exposure Method (OEM), as alternatives approaches for institutions that
meet predefined eligibility criteria.
47.In addition, the information available in the current COREP templates C07.00 and C08.01 on credit
and counterparty credit risks and free deliveries, has been deemed inadequate for supervisory and
analysis purposes. This was already mentioned in the EBA response to the EU Commission call for
advise on SA CCR and OF requirements for Marker Risk (Nov 2016) that recommended i) one or
more CCR COREP templates giving an overview of the CCR of institutions; and ii) COREP
cells/templates providing details on the computation of the different proportionality thresholds
5
https://eba.europa.eu/documents/10180/1360107/EBA+Report+on+the+regulatory+review+of+the+IRB+Approach.pdf
6
Please refer to the BCBS SA-CCR standards, available under https://www.bis.org/publ/bcbs279.htm
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included in the legislation. Therefore, due to the updates of the CRR2 and the
lack of information in the ITS, additional information has been added.
48.In order to allow supervisors to monitor whether the institutions meet the predefined eligibility
criteria to apply the more simplified standard methods/approaches, information for the calculation
of the thresholds (C34.01) has now been included in the ITS.
49.The current information on counterparty credit risk data included in COREP, does not provide either
an overview of the CCR of the institutions or specific information on the methodology used to
compute the exposure value, i.e. on the CCR approach. To fill in these data gaps, information by
risk categories in the case of the standardised approaches and by instrument in the case of IMM
(C34.02 to C34.05) has been introduced providing relevant information for the calculation for the
CCR exposure value and their link to the risk weighted exposure amounts. Templates with
information with the composition of collateral (C34.08) and the breakdown of credit derivative
exposures (C 34.09) and exposures to central counterparties (C34.10) have also been added. This
new information provides the supervisors with a deeper insight on the risks potentially faced by the
institutions depending on the composition of their derivative/SFTs portfolio and on the composition
of the collateral received.
50.Moreover, information on the top 20 counterparties with higher counterparty credit risk exposure,
has also been incorporated (C 34.06). It allows supervisors to have an overview towards which
entities reside the most relevant counterparty credit risk exposures of the reporting institution. It
provides information on the concentration of CCR and the countries where the counterparties are
established. It allows to analyse if the counterparties are connected clients and thus likely to expose
the institution to a single higher risk.
51.Finally, the instructions in the current COREP templates have been updated to align them to the
CRR2.
Disclosures alignment
52.The commitment to fully align the disclosure requirements with supervisory reporting means that
all information disclosed by institutions shall be conveyed by supervisory reporting as well. Some
of the new templates introduced focus on ensuring enhanced comparability between institutions
both by supervisors and by the general public. These templates are C34.07 that provides all relevant
parameters used for the calculation of counterparty credit risk capital requirements for IRB models,
and C34.11 that presents a flow statement explaining changes in counterparty credit risk RWA
determined under the Internal Model Method for counterparty credit risk.
53.This data will be subject to validation rules, DPM and taxonomy, as any other reporting template.
Therefore, there will be a better understanding about what exactly is the data being disclosed as
well. Moreover, these reporting templates will be subject to data quality checks by the supervisors,
which, due to the integration with disclosures, will also improve the disclosure data and therefore
allow the general users of information to take more informed decisions.
54.In order to minimize the reporting cost for institutions, it is proposed that these two new templates
introduced are aligned with disclosures in terms of the scope of institutions which have to report
them, and also in terms of frequency. Therefore, only institutions which are subject to these
disclosure requirements have to report these templates and with the same frequency.
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55.The main development for the leverage ratio is the implementation by the CRR2 of 3% leverage
ratio requirement for institutions in the EU applicable from June 2021. At the same time, there are
several changes to the definition of the leverage ratio compared to the leverage ratio delegated act
of October 2014. These changes mostly reflect the changes in the leverage ratio definition as laid
out in the Basel III reforms. Further, there are a number of EU specificities, often leading to
exemptions of certain exposures from the leverage ratio calculation. As a consequence, the
leverage ratio calculation has been adjusted to an important extent, which results in detailed
specifications that need to be reflected in reporting or provisions that may need a period of further
monitoring. The main changes are described in paragraphs below.
56.Articles 429a (1)(d), (1)(e), and (2) of the CRR2 provide exemptions of certain categories of
exposures related to public development credit institutions and promotional loans. As also
illustrated in several diagrams provided in the accompanying documents section 5.1.2 to this CP,
the definitions are new and there appear to be various types of structures in which exposures may
be exempted. Particularly the definition of public development credit institution is rather wide and
to avoid misinterpretation a specific reporting on the type of institution appears necessary. A similar
width of scope can be observed regarding potential issuers of promotional loans and the ultimate
beneficiaries of public sector investments / promotional loans. Monitoring by the EBA and
supervisors is important to understand the grounds for exempting exposures. For this purpose, the
following information has been introduced:
Template C44.00: whether the credit institution is a public development credit institution
or has a public development unit, and information on the guarantee provided to these
credit institutions/units.
Template C47.00 (LRCalc): as the exemption can either be for exposures on public sector
investments or promotional loans of various varieties, the corresponding breakdown is
being requested.
Template C40.00: the ultimate counterparty of public sector investment and promotional
loan exposures exempted in accordance with Article 429a(1)(d) of the CRR. The template is
based on the understanding that this exemption is applicable only to promotional loans
that constitute claims on government/public sector. While subject to further review, it is
not clear whether a wider interpretation would be possible under which this exemption
would apply to promotional loans regardless of the counterparty.
57.The update of the standardised approaches for the counterparty credit risk framework by the CRR2
has been also reflected in the leverage exposure value, specifically by replacing in template C47.00
the mark-to-market (MtM) method for derivatives by the standardised approach for counterparty
credit risk (SA-CCR) and simplified SA-CCR.
58.The treatment of regular-way purchases or sales awaiting settlement is now specifically clarified in
the CRR2. As the transactions have a different balance sheet value at institutions implementing
trade date accounting (i.e. temporary recognition of both cash and the asset) than at institutions
implementing settlement date accounting (i.e. no recognition of the transaction until the
settlement date), separate rows have been added to the reporting template C47.00. For trade date
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59.The treatment of cash pooling arrangements is new in the CRR2, where under certain circumstances
positive and negative balances of clients within a cash pool can be presented as net. For the physical
variant of cash pooling a net representation would require that credit and debit balances are settled
into a single account on a daily basis as in accordance with Article 429b (2) of the CRR. For notional
cash pooling the conditions (listed in Article 429b (3) of the CRR) focus on aspects such as legal
enforceability. The exposures to cash pooling arrangement, and effects of net representation, have
been included in template C 47.00.
60.The CRR2 also imposes, in Article 92(1a), a G-SII add-on for the leverage ratio, which is defined as
half of the % add-on in the RWA based ratio. The templates have been updated to include this
information as of January 2022, i.e. since the moment the G-SII add-on is applicable.
61. Further amendments to the template C 47.00 (LRCalc) following changes in the CRR2:
a. Exempted exposures to the central bank and the associated adjusted leverage ratio
requirement which reflects that the 3% minimum would automatically increase in
proportion to the use of the exposure exemption.
b. Various further exemptions/exclusions new in the CRR2, amongst which: netted pre-
financing or intermediate loans, IPS exposures, guaranteed parts of exposures arising
from export credits, excess collateral deposited at triparty agents, securitised
exposures representing significant risk transfer, CSD related services of CSDs or
designated institutions.
c. The inclusion of general provisions (or “general credit risk adjustments” in the CRR2)
as an item that can be deducted from on-balance sheet items or off-balance sheet
items.
62.An additional change reflected in the template C 47.00 (LRCalc), is the inclusion of Pillar 2
requirements (P2R) and guidance (P2G) in accordance with Article 104a and Article 104b of the
CRD5 which address risks of excessive leverage. To reflect that the capital add-on
requirements/guidance may be of a different quality than Tier 1, the new rows include a breakdown
by CET1, Tier 1, and Total Capital.
63.Finally, Article 430 (2) of the CRR mandates the EBA to create reporting requirements for large
institutions on specific leverage ratio components based on averages over the reporting period, in
order to enable supervisors to monitor leverage ratio volatility. For this purpose it should take into
account ‘a) how susceptible a component is to significant temporary reductions in transaction
volumes that could result in an underrepresentation of the risk of excessive leverage at the
reporting reference date and equally “(b) developments and findings at international level”.
64.In the context of point b) above, the BCBS in June 2019 has published a statement indicating that
for SFT exposures a calculation, and subsequent disclosure, of daily averages would be necessary7.
7
https://www.bis.org/press/p190626.htm
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Therefore, the leverage ratio templates have been updated (new templates
C48.01 and c 48.02) to request large institutions to report based on averages
over the reporting period only for those components requested by the BCBS for disclosure, i.e. for
SFTs. The daily values used by the institutions to calculate those averages are also to be reported.
65.In addition, in cooperation with the BCBS, the EBA will assess whether also other components of
the leverage ratio may be susceptible to significant intra-quarter volatility. Assessing the
significance of each component and how crucial it is (consideration a) above), requires a solid
analysis and assessment. Hence in the future, also other components will be considered for
inclusion in an averaging requirement if warranted.
66.Further, the EBA considers to clarify regarding template C43.00 – which is an already implemented
template providing the breakdown of risk weighted exposure amounts (RWEA) and leverage ratio
exposure according to exposure type – whether the breakdown of the RWEA could take into
account potential substitution effects due to credit risk mitigation (CRM). In any case, with or
without substitution effect, the RWEA reported in C 43.00 is after the RWEA reducing effect of CRM.
One solution, which would be at the expense of comparability, is to perform the exposure type
categorisation of RWEA after substitution (i.e. by guarantor instead of by original obligor), with no
substitution occurring regarding the leverage ratio exposure. Another solution, which preserves
compatibility between the classification of leverage ratio exposure and RWEA, would be to clarify
that RWEA should be classified before any substitution effects due to CRM in accordance with its
original obligor, just as the leverage ratio exposure, even though the RWEA has decreased as a
result of CRM. Yet another option, is to require the reporting of both values, the RWEA as well as
the leverage ratio exposure, after substitution effects.
67.The CRR2 introduces some changes to the large exposure framework. The calculation of large
exposure limits are based on a higher quality of capital (‘eligible capital’ has been replaced by ‘Tier
1 capital). The reporting requirement of exposures of a value greater or equal to EUR 300m but less
than 10% of the institution’s Tier 1 capital on a consolidated basis has been included in the large
exposures reporting. The inclusion of the new large exposures limit between G-SIIs (15% of an
institution’s Tier 1 capital rather than the generic 25%) has been included in template C 26.00 by
adding a new row where institutions shall report the amount of the applicable limit for
counterparties which are institutions or a group which comes to be identified as a G-SII or as a non-
EU G-SII. According to CRR2, substitution approach is now mandatory and the instructions of large
exposures have been amended to reflect this change.
69.The templates on identification of the counterparty (C 27.00), exposures in the non-trading and
trading book (C 28.00) and detail of the exposure to individual clients within groups of connected
clients (C 29.00) have been revised to reflect the guidance provided in some reporting Q&As.
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70.The CRR2 also mandates EBA to further develop several RTS and Guidelines
with regard to large exposures as well as the ITS on supervisory reporting. The
development of the RTS may imply some further changes in supervisory reporting.
3.5.7 NSFR
71.Under the CRR2, institutions will need to comply with a 100% Net stable funding ratio (NSFR)
requirement starting from June 2021. This requirement is new and, therefore, the current reporting
requirements do not convey the necessary information to allow this calculation. The proposal in
this consultation is to replace the previous supervisory reporting on stable funding, which existed
mainly for calibration purposes, by completely new templates that will allow the compliance
monitoring of this new requirement.
72. The new proposed annexes XXVI and XXVII replace for credit institutions Part V of annexes XII and
XIII on Stable Funding: Items requiring stable funding and items providing stable funding. These two
templates (C 60.00 and C 61.00) mainly existed for the purposes of calibrating stable funding
requirements.
73.Two different sets of templates and instructions have been included: one for the standard NSFR
and one for the simplified NSFR, in line with the CRR2. Two templates have been included in each
case; one on available stable funding (ASF) items and another one on required stable funding (RSF)
items. In addition to it, a common summary template has been included for the standard and the
simplified versions.
74.The RSF and ASF templates capture the necessary elements for calculation and supervisory
assessment of the required and available stable funding. The summary template (C 84.00) intends
to capture aggregated items on the main ASF and RSF elements and the value of the NSFR itself,
which is not captured elsewhere. The main ASF and RSF aggregate items provide an overview of
the main components that contribute to the NSFR and, since the items in the summary template
are roughly the same reported in the ASF and RSF templates, this template aims at ensuring
reporting efficiency. This summary template is the same for the standard and simplified versions of
the NSFR in order to allow a comparative analysis across all institutions.
Fully-fledged templates
75.In line with the CRR2, in general all institutions shall report the fully-fledged NSFR templates (C
80.00 and C 81.00). The information that is requested in template C 80.00 refers to the RSF
(denominator of the NSFR) and C 81.00 refers to the ASF (numerator of NSFR). Therefore,
supervisors can analyse the main components of the numerator and denominator of the NSFR and
investigate what are the main contributors to the ratio. Both of these templates include the items
that may be subject to different factors and those items are also aggregated in the main
components so that the templates can be more easily interpreted.
76.The columns are split into three main blocks for both templates:
a. Amount: this should be, in general, the accounting value except for derivatives
contracts;
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c. Applicable factor: may reflect, but are not limited to, firm-specific and national
discretions.
77.Each of these blocks is split into three maturity buckets of the underlying instrument: residual
maturity of less than six months or without stated maturity; residual maturity of at least six months
but less than one year; and residual maturity of one year or more. On top of that, the RSF templates
present an additional “HQLA” column since the factors applied to HQLA items do not depend on
the residual maturity of the instrument but, if being encumbered, on the maturity of the
encumbrance.
78.The items presented in rows capture the necessary elements for calculation and supervisory
assessment of the required and available stable funding, in line with the CRR2. They are split into
the main aggregates/components that affect the calculation of the ASF or RSF.
Simplified templates
79.In line with the CRR2, institutions that are considered small and non-complex may seek
authorization from the competent authority to apply the simplified NSFR and accordingly report
simplified templates (C 82.00 and C 83.00) instead of the fully-fledged ones mentioned in the
section above. These templates reflect an adequate balance for the simplified requirements since
they reflect the main components that contribute to the simplified NSFR and that might be subject
to different factors.
80.The main differences of the simplified templates when compared to the fully-fledged ones are as
follows:
a. The maturity buckets are two instead of three (residual maturity of less than one year
or without stated maturity and residual maturity of one year or more). This applies for
the amount, the standard factor and the applicable factor blocks;
c. The standard factors are more different since they are in line with the CRR2 provisions
for the simplified NSFR requirements.
Finrep
81.The amendments to FINREP other than the ones related to the NPL backstop are driven by: i)
accounting issues (e.g. the presentation of purchased and originated financial assets (POCIs) outside
the IFRS 9 impairment stages); ii) issues raised by Q&As (e.g. the inclusion of cash balances and
other demand deposits in the loss allowance movements) and iii) the need of integration with Pillar
3 framework. In particular, in templates F 04.03.1; F 04.04.1; F 07.01; F 12.01; F 18.00, the
presentation of POCIs has been changed by including ad-hoc columns outside the impairment
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Stages. This presentation is more in line with the specific measurement criteria
of POCIs set out by IFRS 9.
Asset Encumbrance
82.The minor amendments to the Asset Encumbrance module has been introduced to ensure full
alignment with Pillar 3 framework.
83.The Losses from Immovable Property (IP Losses) reporting has been amended with regard to the
reporting frequency (from semi-annual to annual) as mandated by Article 430a of the CRR2. A
further review of the underlying methodology for reporting IP Losses will be undertaken during
2020.
84.Throughout the EBA supervisory reporting, there were different entity identifier solutions. Some
amendments have been done with the purpose to harmonise the use of LEI codes in supervisory
reporting and harmonise practices that enable to identify unequivocally the same entity across
different reporting request.
85.Promoting the use of LEI codes will improve the quality of the data reported reducing redundancy
enabling data processing, aggregation and calculation, assuring the comparability between data
from different sources and times and thereby improve the data quality.
87.The next major framework release will be version v3.0, where changes and new reporting
requirements resulting from the CRR2, CRD V and the BRRD2 will be incorporated.
88.The planned deliverables for implementing the changes driven by the banking package are:
New ITS on supervisory reporting that will replace the Commission Implementing Regulation
(EU) No 680/2014 for consistency and legal certainty reasons, proposed in this consultation
paper (v3.0);
New ITS on reporting on the new market risk requirements (v2.10) and
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Timeline for reporting frameworks to meet CRR2 and BRRD2 reporting mandates
in version 3.0 framework release.
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In between the text of the draft RTS/ITS/Guidelines/advice that follows, further explanations on
specific aspects of the proposed text are occasionally provided, which either offer examples or
provide the rationale behind a provision, or set out specific questions for the consultation process.
Where this is the case, this explanatory text appears in a framed text box.
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of XXX
Having regard to Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26
June 2013 on prudential requirements for credit institutions and investment firms and amending
Regulation (EU) No 648/20128 and in particular the first subparagraph of Article 430(7), second
subparagraph of Article 430(9), and first subparagraph of Article 430b(6) thereof,
Whereas:
(1) Without prejudice to the competent authorities’ powers under point (j) of Article 104(1)
of Directive 2013/36/EU 9 and with a view to increasing efficiency and reducing the
administrative burden, a coherent reporting framework should be established on the
basis of a harmonised set of standards. Commission Implementing Regulation (EU) No
680/201410 specifies, on the basis of Article 430 of Regulation (EU) No 575/2013, the
modalities according to which institutions are required to report information relevant to
their compliance with Regulation (EU) No 575/2013. This Regulation has been
amended several times11, as new prudential elements have been introduced or further
developed or amended in Regulation (EU) No 575/2013.
(2) Regulation (EU) 2019/876 of the European Parliament and of the Council12 (“CRR2”)
amends significantly Regulation (EU) 575/2013 in a number of aspects, such as the
leverage ratio, the net stable funding requirement, requirements for own funds and
eligible liabilities, the counterparty credit risk, market risk, exposures to central
counterparties, exposures to collective investment undertakings, large exposures as well
as reporting and disclosure requirements. These developments call for a revision of the
reporting framework as set out in the Commission Implementing Regulation (EU) No
8
OJ L 176, 27.6.2013, p. 1.
9
Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit
institutions and the prudential supervision of credit institutions and investment firms, amending Directive 2002/87/EC and
repealing Directives 2006/48/EC and 2006/49/EC (OJ L 176, 27.6.2013, p. 338)
10
Commission Implementing Regulation (EU) No 680/2014 laying down implementing technical standards with regard to
supervisory reporting of institutions according to Regulation (EU) No 575/2013 (OJ L 191, 28.6.2014, p. 1).
11
For more detailed analysis of the revisions, see EBA website https://eba.europa.eu/risk-analysis-and-data/reporting-
frameworks
12
Regulation (EU) 2019/876 of the European Parliament and of the Council of 20 May 2019 amending Regulation (EU) No
575/2013 as regards the leverage ratio, the net stable funding ratio, requirements for own funds and eligible liabilities,
counterparty credit risk, market risk, exposures to central counterparties, exposures to collective investment undertakings,
large exposures, reporting and disclosure requirements, and Regulation (EU) No 648/2012, OJ L 150, 7.6.2019, p. 1–225.
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that date in a way that increases their exposure value. The measure
of this prudential backstop is based on the definitions of NPEs and
Forbearance already laid down in the Commission Implementing Regulation (EU) No
680/2014. As a consequence, it is necessary to review the reporting definitions of NPEs
and Forbearance in order to define those terms by reference to the amended Regulation
(EU) No 575/2013 to ensure that a single definition of NPEs and Forbearance for both
reporting and prudential backstop purposes exists. New templates are also necessary for
the collection of information for monitoring the development of NPEs over time as well
as for the backstop calculation.
(9) To ensure legal certainty and consistency and in line with the principle of better
regulation while having regard to the extensive amendments necessary to reflect the new
changes in the prudential framework, it is nececcary to fully repeal the Commission
Implementing Regulation (EU) 680/2014 and replace it with this Regulation.
(10) This Regulation is based on the draft implementing technical standards submitted by the
European Banking Authority (EBA) to the Commission.
(11) EBA has conducted open public consultations on the draft implementing technical
standards on which this Regulation is based, analysed the potential related costs and
benefits and requested the opinion of the Banking Stakeholder Group established in
accordance with Article 37 of Regulation (EU) No 1093/201013 in relation to those.
CHAPTER 1
Article 1
SUBJECT MATTER AND SCOPE
This Regulation lays down uniform reporting formats and templates, instructions and
methodology on how to use those templates, the frequency and dates of reporting, the
definitions and the IT solutions for the reporting of institutions to their competent authorities
pursuant to paragraphs 1 to 4 of Article 430 of Regulation (EU) No 575/2013, paragraph 7
and 9 of Article 430 of Regulation (EU) No 575/2013.
CHAPTER 2
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Article 2
Article 3
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Article 4
1. Institutions, which meet or cease to meet the conditions set out in Article 4(1) points (145)
or (146) of Regulation (EU) No 575/2013, shall commence or, respectively, cease reporting
information as small and non-complex or as large institutions, already on the first reporting
reference date after these conditions have been met or have ceased to be met.
2. Institutions shall commence reporting information subject to thresholds set out in this
Regulation on the on the next reporting reference date after these thresholds have been
exceeded on two consecutive reporting reference dates. Institutions may stop reporting
information subject to thresholds set out in this Regulation on the next reporting reference
date provided they have fallen below the relevant thresholds on three consecutive reporting
reference dates.
CHAPTER 3
Article 5
1. In order to report information on own funds and on own funds requirements according
to point (a) of Article 430(1) of Regulation (EU) No 575/2013 on an individual basis,
institutions shall submit information as set out in the following paragraphs with a quarterly
frequency. Institutions shall submit information according to paragraphs 2 to 14 of this
Article.
Large institutions which are either G-SIIs or their shares have been admitted to trading in a
regulated market shall also submit information according to paragraphs 15 and 16.
2. Information relating to own funds and own funds requirements shall be submitted as
specified in templates 1 to 5 of Annex I, according to the instructions in Part II point 1 of
Annex II.
3. Information on credit risk and counterparty credit risk exposures treated under the
Standardised Approach shall be submitted as specified in template 7 of Annex I, according
to the instructions in point 3.2 of Part II of Annex II.
4. Information on credit risk and counterparty credit risk exposures treated under the
Internal Rating Based Approach shall be submitted as specified in template 8.1 and 8.2 of
Annex I, according to the instructions in point 3.3 of Part II of Annex II.
5. Information on the geographical distribution of exposures by country, as well as
aggregated at a total level, shall be submitted as specified in template 9 of Annex I, according
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14
Commission Delegated Regulation (EU) 2016/101 of 26 October 2015 supplementing Regulation (EU) No 575/2013 of the
European Parliament and of the Council with regard to regulatory technical standards for prudent valuation under Article
105(14), OJ L 21, 28.1.2016, p. 54–65
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Article 6
1. In order to report information on own funds and on own funds requirements according
to point (a) of Article 430(1) of Regulation (EU) No 575/2013 on an individual basis,
institutions shall submit information as set out in the following paragraphs with a semi-annual
frequency. Institutions shall submit information according to paragraph 2, paragraph 3 and
point (a) of paragraph 4.
Large institutions shall also submit information according to point (b) to (f) of paragraph 4
and paragraph 5.
Large institutions which are either G-SIIs or their shares have been admitted to trading in a
regulated market shall also submit information according to paragraph 6.
2. Information on all securitisation exposures shall be reported as specified in templates 14
and 14.01 of Annex I, according to the instructions in point 3.8 of Part II of Annex II;
3. Information on sovereign exposures shall be submitted in the following manner:
(a) Institutions shall submit the information specified in template 33 according to
the instructions in Part II point 7 of Annex II where the aggregate carrying
amount of financial assets from the counterparty sector General governments is
equal or higher than 1 % of the sum of total carrying amount for Debt securities
and Loans and advances. To calculate the relevant values, institutions shall
follow the instructions for Annex III or Annex IV, as applicable for template 4;
(b) Institutions that meet the criterion referred to in point (a) and where the value
reported for domestic exposures of non-derivative financial assets as defined in
row 10, column 10 of template 33 is less than 90 % of the value reported for
domestic and non-domestic exposures for the same data point, shall submit the
information specified in templates 33 according to the instructions in Part II
point 7 of Annex II but with a full country breakdown;
(c) Institutions that meet the criterion referred to in point (a) but do not meet the
criterion referred in point (b), shall submit the information specified in template
33 according to the instructions in point 7 of Part II of Annex II but with
exposures aggregated at (i) a total level and (ii) a domestic level.
The entry and exit criteria of Article 4(2) shall apply.
4. Information on material losses regarding operational risk shall be reported in the
following manner:
a) institutions which calculate own funds requirements relating to operational risk
according to Chapter 4 of Title III of Part Three of Regulation (EU) No
575/2013, shall report this information as specified in template 17.01 and 17.02
of Annex I, according to the instructions in point 4.2 of Part II of Annex II;
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Article 7
1. In order to report information on own funds and on own funds requirements according
to point (a) of Article 430(1) of Regulation (EU) No 575/2013 on an individual basis,
institutions shall submit information as set out in the following paragraphs with annual
frequency. Large institutions shall submit information according to paragraph 2.
Large institutions which are neither G-SIIs nor have their shares been admitted to trading in
a regulated market shall also submit information according to paragraphs 3 to 5.
2. Information on template 8.5, 8.5b, 8.6 and 8.7 of Annex I on credit risk and counterparty
credit risk exposures treated under the Internal Rating Based Approach shall be submitted
solely by large institutions, according to the instructions in point 3.3 of Part II of Annex II.
3. Information on template 8.4 of Annex I on credit risk treated under the Internal Rating
Based Approach shall be submitted solely by large institutions which are neither G-SIIs nor
have their shares been admitted to trading in a regulated market, according to the instructions
in point 3.3 of Part II of Annex II.
4. Information on template 34.11 of Annex I on counterparty credit risk shall be submitted
solely by large institutions which are neither G-SIIs nor have their shares been admitted to
trading in a regulated market, according to the instructions in point 3.9.12 of Part II of Annex
II.
5. Information on template 34.07 of Annex I on counterparty credit risk, which shall be
reported only by large institutions which are neither G-SIIs nor have their shares been
admitted to trading in a regulated market, according to the instructions in point 3.9.8 of Part
II of Annex II.
Article 8
In order to report information on own funds and own funds requirements according to point
(a) of Article 430(1) of Regulation (EU) No 575/2013 on a consolidated basis, institutions
shall submit:
(a) the information specified in Articles 5, 6 and 7 on a consolidated basis with the
frequency specified therein;
(b) the information specified in template 6 of Annex I according to the instructions
provided in point 2 of Part II of Annex II regarding entities included in the scope of
consolidation, with a semi-annual frequency.
Article 9
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Article 10
1. Investment firms that make use of the transitional provisions of Article 57 point (3) of
Regulation (EU) 2019/xxxx [Investment firms Regulation] shall submit information as set out
in the following paragraphs.
2. In order to report information on own funds and on own funds requirements according to
point (a) of Article 430(1) of Regulation (EU) No 575/2013 on a consolidated basis, with the
exception of information on the leverage ratio, investment firms of groups which consist only
of investment firms making use of Article 57 (3) of IFR with reference to Article 95 of
Regulation (EU) No 575/2013 shall submit the following information on a consolidated basis:
(a) the information on own funds and own funds requirements as specified in templates 1 to
5 of Annex I according to the instructions in point 1 of Part II of Annex II, with a quarterly
frequency;
(b) the information on own funds and own funds requirements regarding entities included in
the scope of consolidation as specified in template 6 of Annex I, according to the
instructions in point 2 of Part II of Annex II, with a semi-annual frequency.
3. In order to report information on own funds and on own funds requirements according to
point (a) of Article 430(1) of Regulation (EU) No 575/2013 on a consolidated basis, investment
firms of groups which consist of investment firms subject to both Article 95 and Article 96 as
well as groups which consist only of investment firms making use of Article 57 (3) of IFR
with reference to Article 96 of Regulation (EU) No 575/2013 shall submit the following
information on a consolidated basis:
(a) the information specified in points (1) to (5), point (7) to (12) and point (15) of Article 5
of this Regulation and point (2) of Article 6 of this Regulation with the frequency
specified therein.;
(b) the information regarding entities included in the scope of consolidation as specified in
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CHAPTER 4
Article 11
33
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Article 12
CHAPTER 5
34
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Article 13
CHAPTER 6
Article 14
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CHAPTER 7
Article 15
1. In order to report information on the leverage ratio according to point (a) of Article 430 (1) of
Regulation (EU) No 575/2013 on an individual and a consolidated basis, institutions shall
submit the information specified in Annex X according to the instructions in Annex XI, with
a quarterly frequency. Template 48.00 shall be submitted by large institutions only.
2. The cell {r350;c010} in template 40.00 shall only be reported by:
i.large institutions which are either G-SIIs or their shares have been admitted to trading
in a regulated market with a semi-annual frequency,
ii. large institutions which are neither G-SIIs nor have their shares been admitted to
trading in a regulated with an annual frequency,
iii. other institutions than large institutions and small and non-complex institutions,
which shares have been admitted to trading in a regulated with an annual frequency.
3. Institutions shall calculate the leverage ratio at the reporting reference date in accordance
with Article 429 of Regulation (EU) No 575/2013.
4. Institutions shall report the information referred to in paragraph 13 of Part II of Annex XI
if one of the following conditions is met:
(a) the derivatives share referred to in paragraph 5 of Part II of Annex XI is more than 1,5 %;
(b) the derivatives share referred to in paragraph 5 of Part II of Annex XI exceeds 2,0 %.
The entry and exit criteria of Article 4(2) shall apply, except for point (b) where institutions shall
start reporting information from the next reporting reference date, where they have exceeded
the threshold on one reporting reference date.
5. Institutions for which the total notional value of derivatives as defined in paragraph 8 of
Part II of Annex XI exceeds 10 billion euro shall report the information referred to in
paragraph 13 of Part II of Annex XI, even though their derivatives share does not fulfil the
conditions described in paragraph 3.
The entry criteria of Article 4(2) shall not apply. Institutions shall start reporting information
from the next reporting reference date where they have exceeded the threshold on one
reporting reference date.
6. Institutions are required to report the information referred to in paragraph 14 of Part II of
Annex XI where one of the following conditions is met:
(a) the credit derivatives volume referred to in paragraph 9 of Part II of Annex XI is more than
EUR 300 million;
(b) the credit derivatives volume referred to in paragraph 9 of Part II of Annex XI exceeds
EUR 500 million.
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The entry and exit criteria of Article 4(2) shall apply, except for point (b) where
institutions shall start reporting information from the next reporting reference
date where they have exceeded the threshold on one reporting reference date.
CHAPTER 8
Article 16
1. In order to report information on the liquidity coverage requirement according to point (d)
Article 430(1) of Regulation (EU) No 575/2013 on an individual and consolidated basis,
institutions shall submit the information specified in Annex XXIV according to the
instructions in Annex XXV with a monthly frequency;
2. The information set out in Annex XXIV shall take into account the information submitted
for the reference date and the information on the cash-flows of the institution over the
following 30 calendar days.
Article 17
In order to report information on the stable funding according to point (d) Article 430(1) and
Article 415 of Regulation (EU) No 575/2013 on an individual and consolidated basis,
institutions shall submit the information specified in Annex XXVI according to the
instructions in Annex XXVII with a quarterly frequency.
CHAPTER 9
Article 18
In order to report information on additional liquidity monitoring metrics according to point (d) of
Article 430(1) and point (b) of Article 415(3) of Regulation (EU) No 575/2013 on an individual
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CHAPTER 10
Article 19
1. In order to report information on asset encumbrance in accordance with point (g) of Article 430(1)
of Regulation (EU) No 575/2013 on an individual and a consolidated basis, institutions shall
submit the information specified in Annex XVI to this Regulation according to the instructions set
out in Annex XVII to this Regulation.
2. The information referred to in paragraph 1 shall be submitted according to the following
specifications:
(a) the information specified in Parts 1, 2 and 4 of Annex XVI with a quarterly frequency;
(b) the information specified in Part 3 of Annex XVI with an annual frequency;
(c) the information specified in Part 5of Annex XVI with a semi-annual frequency.
3. Institutions shall not be required to report the information in Parts 2, 3 and 5 of Annex XVI where
all of the following conditions are met:
(a) the institution is not considered a large institution;
(b) the asset encumbrance level of the institution, as calculated in accordance with paragraph
9 of point 1.6 of Annex XVII, is below 15 %.
The entry and exit criteria of Article 4(2) shall apply.
4. Institutions shall only be required to report the information in Part 4 of Annex XVI where they
issue bonds referred to in the first subparagraph of Article 52(4) of Directive 2009/65/EC of the
European Parliament and of the Council15. The entry and exit criteria of Article 4(2) shall apply.
CHAPTER 11
15
Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws,
regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS)
(OJ L 302, 17.11.2009, p. 32).
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Article 20
1. Institutions shall submit the information referred to in this Regulation in the data exchange
formats and representations specified by competent authorities and respecting the data point
definition of the data point model set out in Annex XIV and the validation formulae specified
in Annex XV as well as the following specifications:
(a) information that is not required or not applicable shall not be included in a data
submission;
(b) numeric values shall be submitted as facts according to the following:
i. data points with the data type ‘Monetary’ shall be reported using a minimum precision
equivalent to thousands of units;
ii. data points with the data type ‘Percentage’ shall be expressed as per unit with a minimum
precision equivalent to four decimals;
iii. data points with the data type ‘Integer’ shall be reported using no decimals and a
precision equivalent to units.
(c) Institutions shall be identified solely by their Legal Entity Identifier (LEI). Legal entities
and counterparties other than institutions shall be identified by their LEI where available.
2. The data submitted by the institutions shall be associated with the following
information:
(a) reporting reference date and reference period;
(b) reporting currency;
(c) accounting standard;
(d) identifier of the reporting institution (LEI);
(e) scope of consolidation.
CHAPTER 12
FINAL PROVISIONS
Article 21
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Article 22
This Regulation shall enter into force on the twentieth day following that of its publication
in the Official Journal of the European Union.
It shall apply from 28 June 2021.
This Regulation shall be binding in its entirety and directly applicable in all Member
States.
Done at Brussels,
For the
Commission The
President
On behalf of the
President [Position]
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LIST OF ANNEXES
Annexes marked with an asterisk (*) will form part of the new ITS, but are not part of this
consultation, as no major changes are expected compared to Regulation (EU) No 680/2014
(v2.9).
Annex I (Solvency)
Annex II (Solvency)
Annex IV (FINREP)
Annex V (FINREP)
Annex X (Leverage)
Annex XI (Leverage)
Annex XV (VR) *
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5. Accompanying documents
The box below presents the formula and the steps for the calculation of minimum coverage
requirement and the applicable amount of insufficient coverage.
𝑣𝑖
∈ 𝑉{′ <= 1 𝑦𝑒𝑎𝑟′|′ > 1 𝑦𝑒𝑎𝑟; <= 2 𝑦𝑒𝑎𝑟𝑠′|′ > 2 𝑦𝑒𝑎𝑟𝑠; <= 3 𝑦𝑒𝑎𝑟𝑠′| … |′ > 7 𝑦𝑒𝑎𝑟𝑠′}
Step 1: Institutions shall calculate the minimum coverage requirements (MCE) exposure-by-
exposure, and separately for secured and unsecured part of NPEs.
𝐹𝑜𝑟 𝑒𝑎𝑐ℎ 𝑏𝑢𝑐𝑘𝑒𝑡 𝑣 ∈ 𝑉:
𝐼𝑣 𝑎𝑟𝑒 𝑎𝑙𝑙 𝑡ℎ𝑒 𝑒𝑥𝑝𝑜𝑠𝑢𝑟𝑒𝑠 𝑜𝑓 𝑡ℎ𝑎𝑡 𝑏𝑢𝑐𝑘𝑒𝑡
Step 2: Institutions shall calculate total provisions and adjustments or deductions (uncapped,
i.e. not limited to the amount of minimum coverage requirements) corresponding to individual
exposures16 by summing the items specified in the template and point (b) of Article 47c of the
CRR. For partially secured exposures, the total provisions and adjustments or deductions shall
16
In case a deduction is not calculated at exposure but at portfolio level (i.e. IRB shortfall), the total calculated deduction
should be allocated to each exposure weighted by the exposure value.
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be allocated first to the unsecured part of the non-performing exposure and then to the
secured part of the same non-performing exposure.
Step 3: Institutions shall calculate the total provisions and adjustments or deductions limited to
the minimum coverage requirements (i.e. total provisions and adjustments or deductions
(capped)). The calculations shall be at the exposure level. This allows the aggregation of
coverage gaps without taking into account the excess of coverage that institutions may have on
individual exposures.
For each time interval, v, institutions shall report the total minimum coverage requirement for
unsecured part of NPEs (aggregate level) in row 0030, and shall report the total minimum
coverage requirement for secured part of NPEs (aggregate level) in row 0040.
Institutions shall report the total minimum coverage requirement (including both unsecured
and secured parts of NPEs) in row 0020, for each time interval, v.
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= ∑ 𝐶𝑖𝑈𝑛𝑠𝑒𝑐𝑢𝑟𝑒𝑑 + ∑ 𝐶𝑖𝑆𝑒𝑐𝑢𝑟𝑒𝑑
𝑖 𝑖
For each time interval, v, this total amount shall be reported in row 0090 and the sum of the
individual components of 𝐶𝑖 shall be reported in rows 0100-0150.
Step 6: Institutions shall calculate ‘Total provisions and adjustments or deductions (capped)’
as:
𝐼𝑣
Institutions shall report the total provisions and adjustments or deductions (capped) in row
0080, for each time interval, v.
Step 7: Institutions shall calculate the applicable amount of insufficient coverage, defined as
the difference between the total minimum coverage requirement (row 0020) and the total
provisions and adjustments or deductions (capped) (row 0080) under each time bucket.
The applicable amount of insufficient coverage should be equal to or greater than zero.
Institutions shall report applicable amount of insufficient coverage in row 0010, for each time
interval, v.
Step 8: Institutions shall sum applicable amount of insufficient coverage across all time
intervals to calculate and report the applicable deductions from CET1.
The diagrams below illustrate the structure by which a Public development credit
institution (PDCI) or unit provides a public sector investment, which is exempted from the
leverage ratio exposure measure following article 429a(1)(d) and (2) of the CRR2 .
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1.1 Example: Exempted Public sector investments by PDCIs (only if 429a(1)(d) and (2) are
met)
1.2 Example: Exempted Public sector investments by PDCIs Units (only if 429a(1)(d) and
(2) are met)
The diagrams below illustrate the treatment of different types of structures for granting a
promotional loan by different credit institutions involved in the process.
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47
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5.1.3 NSFR
The following examples are only included for illustrative purposes and follow the letter of the
instructions as part of the ITS which clearly indicate their substantiation.
100 80 50 30 10 20
50 90 10 20 10 5
Proposed treatment:
An amount of -15 (5 – 20) would be reported as a liability in the all currencies return.
Following Article 428e of the CRR2, netting positions by residual maturity seems logical here.
Netting assets and liabilities above one year would lead to either 100% RSF or ASF factor to be
applied and reported. Netting assets and liabilities with a residual maturity of at least six months
but less than one year would generally apply 50% RSF or ASF factor and would be reported
accordingly. For those instruments where the residual maturity is less than six months, where there
is a liability net position it would generally trigger a 0% or 50% ASF factor if stemming from a
financial or non-financial. However, for those instruments where the residual maturity is less than
six months and where there is an asset net position, this could stem from netting reverse repos
subject to different RSF factors (e.g. 0% if interbank and collateralised by level 1 HQLA excluded
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extremely high quality covered bonds or 5% if collateralised otherwise). The Instructions clarify that
the higher RSF factor (5%) should apply here following paragraph 3 of Article 428c.
This excel file is exclusively intended to be a clarifying example of the practical application of the
NSFR instructions and the templates included in the draft ITS but has no legal value, does not form
part of the ITS, does not discharge institutions from their obligation of reporting every item as
required in the ITS and does not exempt them from their responsibility when reporting. This tool is
just provided for informative purposes and in no case the reporting may be substantiated by it. This
calculation tool is provided for consultation purposes only and will not be part of the final ITS to be
submitted to the EU Commission. The result of these calculations will be included directly in the
validation rules to be developed, along with the Data Point Model and Taxonomy.
This analysis presents the IA of the main policy options included in this Consultation Paper (CP) on
the package of the draft supervisory reporting templates and instructions for framework v 3.0
following changes of the CRR2 and new Backstop Regulation. The IA is high level and qualitative in
nature.
Several regulatory changes have taken place globally and at European level over recent years. The
CRR2 establishes several new prudential requirements, including changes to Credit Risk, Market
Risk, Pillar 3, Counterparty Credit Risk (CCR), the leverage ratio, large exposures and the NSFR. In
addition, another amendment to the CRR has been adopted in April 2019 on minimum loss
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coverage for non-performing loans (NPLs).17 The new legislation requires institutions to set aside
funds to cover for losses on new loans that turn into non-performing.
Whilst some of the new requirements are linked to reporting directly, many other changes are not
explicitly referring to reporting in the Level 1 texts. Nevertheless, they still necessitate amendments
to the existing reporting framework: Changes in definitions or new prudential requirements imply
that the reporting templates used to-date in many places will be outdated once the CRR2 comes
into force in 2021, as they do not reflect the latest regulatory requirements or definitions.
Reflecting the CRR2 and the new Backstop Regulation in EBA’s reporting framework involves
changes to several different templates. The impact assessment at hand discusses all these changes
as part of one assessment: all template amendments- whilst in some cases of different nature and
scope- have been performed in the same context and for the same reason.
B. Policy objectives
The draft proposed reporting templates and instructions aim at aligning the European reporting
framework with changes in the CRR2 and the new regulation on minimum loss coverage for NPLs.
Alignment is crucial in order to ensure institutions’ reporting follows the latest prudential
requirements and to safeguard consistency in reporting, enabling accurate and uniform
measurement and reporting by all institutions across the EU.
Section C. presents the main policy options discussed and the decisions made during the
development and amendments of the templates and instructions. Advantages and disadvantages,
as well as potential costs and benefits of the policy options and the preferred options resulting from
this analysis, are reported.
Reflecting the CRR2 and the new Backstop Regulation in the EBA’s reporting templates involves
change to several different templates. As discussed above, these changes are all discussed as part
of one impact assessment, however, the below assessment will reflect the different forms of
template changes involved. Options are categorised into two groups. One represents overarching
options and policy choices that apply to all templates (or many templates), and another group
covers more specific changes related to individual templates and topics. The policy options
considered as part of the drafting and outlined below are structured along this categorisation.
17
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 575/2013 as
regards minimum loss coverage for non-performing exposures
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There are commonalities of the information that institutions have to report to their supervisors and
the regulatory information that they have to make public in the interest of investors and external
stakeholders. The information included in the reporting framework is the basis for supervisors and
resolution authorities to form a clear picture of an institution’s situation in terms of business
model/profitability, solvency/risk profile, liquidity and relevance for the financial system and
resolvability. Similarly, the information disclosed by institutions is the basis for market participants
to understand and assess institutions’ situation in order to exercise market discipline. Information
relevant for market participants is also relevant for supervisors in their regular tasks, highlighting
the importance to strive for alignment.
Improving the consistency between the reporting and disclosure requirements, including a
standardisation of formats and definitions, should also facilitate the compliance with both
requirements for institutions, as they would use the same data to fulfil their reporting and
disclosure obligations. Further, the integration with supervisory reporting will improve the quality
of the disclosed information since the latter will be subject to supplementary scrutiny by the
supervisor. This will benefit all market participants, enabling them to take more informed decisions.
Therefore, Option 1a has been chosen as the preferred option.
Option 2a: In addition to the newly introduced COREP template C 35.01 on the calculation of the
NPL backstop, introduce a new template on the vintage of exposures classified as non-performing
also in FINREP
Option 2b: Do not introduce a new template on the vintage of non-performing exposures in
FINREP
The introduction of the NPL backstop calculation in the legislation requires the introduction of a
new set of prudential templates. This is reflected in the new COREP templates C35.01, C35.02 and
C35.03 which contain all the information needed for the calculation of the NPE loss coverage and
capital requirements within the framework of CRR Pillar 1 measures. These new templates are of a
purely prudential nature, capturing items such as minimum coverage requirements for unsecured
and secured NPEs by vintage (i.e. by time passed since an exposure has been classified as non-
performing).
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The reporting of non-performing exposures by using the same vintage provided in the new COREP
templates is also important from an accounting point of view, to allow supervisors to monitor
institutions’ NPE coverage strategies more effectively and capture their risk profiles more
accurately: The vintage of a bank’s non-performing portfolio is crucial for the analysis of expected
credit loss provisions and supervisors should assess the way institutions apply the impairment
requirements under IFRS9 (and similar requirements under national GAAPs) in order to assess any
(additional) capital requirement under the SREP process. Furthermore, the vintage of a bank’s non-
performing portfolio can give key indications about the institution’s ability to clean its books and
whether there are more fundamental structural problems in the business model. Therefore,
information on the stocks and provisions of an institution’s non-performing exposure portfolio by
vintage is also important from an accounting perspective. For this reason, Option 2a has been
chosen as the preferred option: it is important to introduce a tool to monitor the vintage of non-
performing exposures also under the accounting framework and hence a new template is proposed
to be introduced also as part of FINREP, namely template F39.00. The added value of being able to
monitor the development of NPEs over time has been assessed to outweigh the additional
reporting cost on institutions. In order to limit the latter, the new reporting template within FINREP
is proposed to be completed and submitted at semi-annual frequency only (versus a quarterly
frequency for the corresponding COREP templates).
Option 3b: Keep FINREP changes to the NPE related changes above
Changes to the COREP templates in the form of introducing new templates for the NPL backstop,
have been proposed following the Regulation (EU) No 2019/630 amending Regulation (EU) No
575/2013 that sets out uniform minimum levels of coverage to ensure that institutions have
sufficient loss coverage for future NPEs. The EBA acts on mandates from level 1 texts (Art. 430(7)
of the CRR), but also always strives to work towards improving the functioning and safety of the
European banking system. This objective is not only met through acting on specific mandates from
the European Commission, but also through dialogue and interaction with the industry and
competent authorities. The latter, in particular through the EBA’s Q&A tool, can provide valuable
information for identifying short-comings in existing regulation or technical standards. In the
specific context of the consultation paper at hand, experience and exchange over the last years
have identified room for improvement and increased clarity in certain existing FINREP reporting
templates, in addition to the changes proposed under the previous option.
Amending reporting templates always incurs some (initial) costs to institutions and competent
authorities alike. Changes and the timing of these amendments are therefore always duly reflected
on and discussed. Introducing changes to the FINREP framework to make reporting more efficient
for institutions and competent authorities, to improve reporting consistency across institutions and
reporting alignment with legislation, has been assessed to make sense at this stage. FINREP
instructions on the definition of non-performing exposures and forbearance are being revisited in
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CONSULTATION PAPER ON DRAFT ITS ON SUPERVISORY REPORTING
any case in the context of the NPL backstop. Performing the additional FINREP changes now, implies
that institutions can implement the changes all at once, which should reduce the additional costs
incurred. Therefore, Option 3a has been chosen as the preferred option.
Option 4a: Create a new template C 08.03, which includes a supervisory master scale
Option 4b: Merge the information necessary for template C 08.03 (breakdown by PD ranges) in
template C 08.02
In the context of EBA’s new mandates on developing an extensive disclosure framework under
CRR2, it is important to ensure that the reporting framework is aligned as far as possible, to
safeguard consistency and efficiency and minimise the reporting and disclosure cost for institutions.
Inter alia, a new disclosure requirement on IRB information, to be broken down by predefined PD
ranges/supervisory master scales, has been introduced following the Basel III reforms on IRB
disclosures. Some of this information is already included in template C 08.02, where IRB exposure
classes are broken down by obligor grade. It could be argued that information on PD ranges could
be derived from template C 08.02 by aggregating the obligor grades representing a specific PD
range.
However, about 20% of institutions use continuous PDs 18 and therefore it is not always possible to
conclude on the PD range an obligor grade falls into from template C 08.02. Therefore, and for the
sake of comparability between institutions, it has been assessed that Option 4a is the preferred
option, introducing a new template C 08.03 containing a supervisory master scale with PD ranges.
IRB – Inclusion of changes resulting from the IRB roadmap
Option 5a: Include changes coming from the IRB roadmap in the reporting framework V 3.0
Option 5b: Include changes coming from the IRB roadmap in the reporting framework V 3.1
In February 2016 the EBA set out a roadmap on the implementation of the regulatory review of the
IRB approach. 19 The three main areas outlined in order to repair and restore trust of IRB models
were: i) review of the regulatory framework; ii) ensuring supervisory consistency, including EBA
benchmarking exercises; iii) increased transparency, based on standardised disclosure templates
and improved reporting.
Following the publication of several EBA products that have resulted from the IRB roadmap, some
changes/additional information are deemed as critical also in supervisory reporting. Since IRB
reporting is subject to several changes already as part of the development of reporting framework
18
See EBA Report on IRB modelling practices.
19
https://eba.europa.eu/-/eba-sets-out-roadmap-for-the-implementation-of-the-regulatory-review-of-internal-models
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V 3.0 following CRR2 and the alignment with disclosure requirements, it could be argued that this
is a good opportunity to already integrate also the changes ensuing from the IRB roadmap.
Whilst this early integration could potentially reduce the costs to institutions in terms of the
changes usually required when implementing reporting framework updates, several EBA products
being brought about by the roadmap, and which might substantially impact reporting, are still
under development (eg. CRM). Therefore, Option 5b has been chosen as the preferred option and
changes resulting from the EBA roadmap will be implemented as part of the next reporting
framework v 3.1. This will ensure that they are final and minimises the need of future changes.
Option 6a: Request the new IRB and CCR reporting templates arising from the alignment with
disclosure templates only from those institutions to which the disclosure requirements apply
Option 6b: Request the new IRB and CCR reporting templates arising from the alignment with
disclosure templates from all institutions
CRR2 Articles 433a requires large institutions to disclose certain information on CCR and IRB. To
integrate disclosure requirements into reporting requirements, one could ask reporting of this
information on CCR and IRB from all institutions (not only large ones), which in the case of IRB
would imply only medium to large institutions since they are the only ones applying IRB. In the case
of CCR this would imply all institutions with counterparty credit risk, irrespectively of their size, but
could be useful information since COREP does not provide much information about this risk type.
The other option is to align the reporting obligations with the CRR2 disclosure obligations in terms
of the scope of institutions to report/disclose, also in terms of frequency. This way, only institutions
which are subject to these disclosure requirements (large institutions) would have to report the
same templates to supervisors and with the same frequency. No further information would have
to be collected or calculated.
In order to ensure reporting efficiency on medium-sized and small and non-complex institutions,
Option 6a has been chosen as the preferred option. In line with the disclosure templates, only
large institutions will be subject to the aligned reporting templates.
Option 7a: Keep the status quo, updating the instructions to reflect the changes introduced by
the CRR2
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Currently, all information on CCR is included as part of the credit risk templates, C 07.00 and C
08.01. The information available in the current COREP templates is deemed insufficient and
inadequate for supervisory and analysis purposes. The EBA response to the EU Commission’s call
for advise on SA CCR and OF requirements for Marker Risk (Nov 2016) recommended to introduce
additional information on CCR. In particular, specific information on the methodology used to
compute the CCR exposure value or the composition of collateral is deemed relevant to provide the
supervisors with a deeper insight on the risks potentially faced by the institutions.
Therefore, the option to keep the status quo has been considered as sub-optimal. Instead, Option
7b has been assessed as the preferred option. Additional information on CCR is needed to ensure
as comprehensive a supervisory assessment as possible.
Option 8a: Add only a summary template for the different CCR approaches/methods
Option 8b: Add individual templates for the different approaches/methods as well as detailed
information on collateral and credit derivatives exposures
During the discussions and design of the templates it has been concluded that information on the
various CCR approaches and additional information is needed, with a substantial degree of
granularity. It is crucial for competent authorities in their supervisory functions to understand an
institution’s risk as much as possible.
Namely, additional information by risk categories in the case of the standardised approaches and
by instrument and margined and unmargined business in the case of IMM, is therefore highly
relevant. The requested additional information can provide supervisors with a deeper insight into
the risks (potentially) faced, depending on the composition of the derivative/SFTs portfolio of the
institution and on the composition of the collateral received. For instance, a portfolio that shows
exposure concentrated in a specific risk category should be closely monitored, in order to ensure
that the potential future exposure is adequately measured. Another example is that an institution
may have a large amount of the same type of collateral and the risk of an impact in its quality.
The option to include simply a summary template on the various CCR approaches has therefore
been assessed as sub-optimal. Instead, Option 8b has been assessed as the preferred option.
Option 9a: Request the reporting of all the leverage components potentially susceptible to intra
quarter volatility based on averages over the reporting period
Option 9b: Request the reporting based on averages over the reporting period only for those
components requested by the Basel Committee for disclosure (reporting using day-end values)
and complement with further analysis that could lead to revisions in the future
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Pursuant to Article 430(7) of the CRR2, the EBA is required to submit a revised reporting framework
on the leverage ratio within 1 year after publication of the CRR2 in the Official Journal. Specifically,
CRR2 Article 430(2) mandates the EBA to create reporting requirements for leverage ratio
components in order to be able to monitor leverage ratio volatility. Importantly, in the design of
this reporting framework, EBA is to i) specify which components of the leverage ratio shall be
reported, ii) decide whether this is to be done using day-end or month-end values. Considerations
should take into account ‘a) how susceptible a component is to significant temporary reductions in
transaction volumes that could result in an underrepresentation of the risk of excessive leverage at
the reporting reference date and equally ‘(b) developments and findings at international level’.
In the context of point b), the BCBS in June 2019 has published a statement indicating that for SFT
exposures (but no derivative or central bank exposures), averaging and disclosure would be
necessary.20 Disclosure of other items has been decided against at the BCBS due to concerns related
to confidentiality (Central Bank emergency liquidity) and the ability of smaller institutions to collect
averages.
Discussions are ongoing on the components for which average values should be reported at
European level. Assessing the significance of each component and how crucial it is to have
additional reporting (consideration a) above), in addition to monitoring of institutions under Pillar
2, requires a solid analysis and assessment. Therefore, Option 9a, to include all components in the
reporting framework, has been rejected for the time being, but may be revisited at a later stage.
For now, only information on the same components required for disclosure by Basel are included
in the reporting framework, in particular the mean of SFT exposure values and the mean of the
adjustments for the SFT sales accounting transactions in a new template C 48.01. In terms of
additional cost for institutions, this implies daily calculations need to be made by large institutions
on SFT exposure values. Following Article 430(2) of the CRR2, the daily values used for the
calculation of the means are also included in a new template C 48.02. This CP includes questions on
the additional cost to large institutions, in order to assess the feasibility to include additional
components of the leverage ratio based on averages over the reporting period. Option 9b has been
chosen as the preferred option for the time being.
With the aim to minimise the number of times that reporting templates are revised and thereby
minimise institutions’ changes and related costs (see also the discussion at the beginning on Option
7), as part of the revision of the leverage ratio templates to reflect the new CRR2 requirements,
20
https://www.bis.org/press/p190626.htm
21
Template C 41.00 corresponds to On- And Off-Balance Sheet Items - Additional Breakdown Of Exposures (LR2), and
template C 42.00 to Alternative Definition Of Capital (LR3)
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also those templates not affected by the new legislation have been reviewed as to ensure that
reported and collected information remains accurate and relevant.
Notably, as part of this assessment, templates C 41.00 and C 42.00 have been identified to contain
information solely collected for the purpose of past monitoring reports: C 41.00 contains the
distribution of exposures across risk weight buckets, collected mostly with the purpose of
monitoring uprisking/downrisking as part of the 2016 EBA report on the leverage ratio
requirements under Article 511 of the CRR 22 , and C 42.00 contains data on the alternative
definition of capital information, which served the purposes of calculating the impact of the choice
of a CET1 or TC numerator, also as part of the 2016 EBA leverage ratio report.
Given this report has been completed, it has been assessed that the information collected as part
of the two templates are not needed for the calculation of the leverage ratio and contain
components that are no longer important for supervisory monitoring purposes. As a result, Option
10b has been chosen as the preferred option, substantially reducing the reporting cost for
institutions.
Leverage - Level of detail on exempted public development credit institution and promotional loan
exposures
Option 11a: Include one additional row on the exemptions related to public development credit
institution and promotional loan exposures (in line with exemptions on other items) in template
C 47.00
Option 11b: Include more detail on the exemptions related to public development credit
institution and promotional loan exposures in template C 47.00
The CRR2 has introduced a Tier 1 capital leverage ratio requirement calibrated at 3%. At the same
time, and in order to avoid that the 3% requirement constrains certain business/activities
disproportionally, the CRR2 provides for some adjustments to the calculation of the leverage ratio
exposure. In general, one row has been included to collect the information for each exemption or
deduction.
One of the exemptions applicable to the calculation of the leverage ratio can be made for public
development bank exposures and exposure to promotional loans. The definitions are new and the
variations in terms of type of exemption are numerous. In particular, the definition of public
development credit institution is rather wide and subject to misinterpretation or arbitrage by
institutions. A similarly broad scope can be observed regarding potential issuers of promotional
loans and the ultimate beneficiaries of public sector investments/ promotional loans. As a result,
implementation of these exemptions is complex. Close monitoring of how institutions apply these
exemptions is crucial in order to understand the grounds for exemptions, avoid misinterpretation
or arbitrage, and thereby ensure a level-playing field of how exemptions are applied by European
institutions.
22
https://eba.europa.eu/documents/10180/1360107/EBA-Op-2016-13+(Leverage+ratio+report).pdf
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As a result, it has been assessed that more granular information is required for the reporting and
monitoring of exemptions on exposures to public development credit institutions and promotional
loans. Accordingly, Option 11b has been chosen as the preferred option.
Specifically, more granular information in the form of additional rows is requested in template C
47.00, inter alia on how a promotional loan is granted (directly, indirectly, via a public development
credit institution or not) and its potential pass-through nature. This is deemed necessary to ensure
appropriate monitoring of the exemptions’ application. In addition, to reflect the need to also
understand the ultimate counterparty of public sector investment and promotional loan exposures
exempted in accordance with Article 429a(1)(d) of the CRR, information on counterparties has been
included in template C 40.00. Finally, information on whether the credit institution is a public
development credit institution or has a public development unit, and information on the
guarantees received, has also been added to template C 44.00.
The CP includes questions on what kind of structures exist, which exposures are exempted in
accordance with Article 429a(1)(d) or (e) of the CRR, and how these structures can be reflected in
the reporting framework. The reporting may be updated based on the feedback received.
In view of proportionality, option 11b aims to achieve an intermediate level of granularity and,
hence, does not include reporting requirements on all aspects, such as on the fulfillment of all the
conditions to be met by public development credit institution in accordance with Article 429a(2) of
the CRR. For example no clarification is requested on whether it has been established by a central
government, regional government of local authority (subparagraph a).
Large Exposures – Inclusion of changes to the Large Exposure regime due to amendments in the
CRR2
Option 12a: Implement the (technical) changes explicitly included in the CRR2 in the reporting
templates and develop further changes once the policy work has progressed.
Option 12b: Implement all the changes resulting from the CRR2 only once also the policy
development has been completed.
In view of the changes to the large exposures regime in part four of the CRR2, a number of technical
changes to the reporting framework are necessary. Some of the changes under the CRR2 imply
technical changes that will not change the structure of the templates, but the definitions and will
imply amendments for the instructions (these include changes such as replacing eligible capital with
Tier 1 capital in Article 395(1) in the definition of the 25% LE limit). Other CRR2 mandates request
a methodological review, requiring additional policy working going forward and the CRR2 mandates
the EBA to develop RTS to further develop the large exposures regime.
Whilst the aim is to always minimise the number of revisions to any reporting template, it has been
assessed that Option 12b, to await until all changes can be implemented, will not be a feasible
option: the current reporting templates on LE reflect certain technical issues incorrectly and
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therefore the reported data would not be in line with the CRR2. Therefore, it has been assessed
that two rounds of revisions would be preferable to having outdated templates and no longer
relevant information reported. As a result, Option 12a has been assessed as the preferred option-
the reporting framework 3.0 will include those technical changes that can be directly derived from
the new CRR2 without further policy work, whilst the rest of the changes will be implemented once
the different CRR mandates are developed through RTS.
The requirement to report maturity buckets has been repealed from the CRR. Whilst this
information could still be collected by the EBA, in order to decrease the reporting cost to
institutions, Option 13b has been chosen as the preferred option and it has been decided to delete
templates C 30.00 and C 31.00 and their respective instructions, in line with the changes in the
CRR2.
NSFR - New column on HQLA for the required stable funding (RSF) templates
Option 14a: Do not introduce a new column and keep the templates as per the QIS
Required stable funding reporting is split into liquid and non-liquid assets as per Basel’s proposed
disclosure templates. Further, the Basel template proposes splitting assets into four maturity
buckets: no maturity (applying to assets such as eg capital with perpetual maturity or physical
traded commodities), < 6months, 6months to 1 year and > 1year.
There is no differentiation by maturity bucket for the factor to be applied for the calculation of
required stable funding for HQLA instruments. All HQLA instruments will be treated the same in the
calculation of the RSF. Hence, there is no rationale for further differentiating this asset class into
maturity buckets, neither for the calculation, nor for the monitoring or reporting. Therefore, the
draft templates propose to introduce an additional column ‘HQLA’, which is not split further into
maturity buckets.
This additional column implies a tremendous increase in reporting efficiency to institutions: in total,
around 200 data points no longer need to be reported with the additional HQLA column in the fully-
fledged RSF template.
The general reporting requirements forthcoming for institutions as part of new and revised
regulation and the continued call for more transparency, are likely to result in increased reporting
costs over the next years. Since the additional break-down of HQLA into maturities is not directly
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relevant for the NSFR calculation or its disclosure, increasing reporting efficiency and making the
templates as effective and user friendly as possible has been identified as the most efficient way
forward and Option 14b has been assessed as the preferred option.
NSFR - Breakdown of the non-financial customers (except central banks) for the available stable
funding (ASF) templates by counterparty
Like for the RSF, different treatments exist for different counterparties for the ASF, according to
ASF factors (0-100%). Liabilities from ‘other non-financial customers (except central banks)’, listed
in rows 2.3.1 to 2.3.6 in template C 81.00, are all subject to the same ASF factor (50%).
Nevertheless, every counterparty included in rows 2.3.1 to 2.3.6 has been listed separately in CRR2
Article 428l. More importantly, in the context of the ASF, the type of counterparty is of importance
since it can hold information about the reliability of the funding source and therefore represents
relevant and helpful information for supervisors.
For these reasons, Option 15b has been chosen as the preferred option and the ASF templates
contain a breakdown of other non-financial counterparties (other than central banks), detailed in
line with CRR2 Article 428l.
The importance of the counterparty type is also inter alia reflected in different ASF factors for other
types of counterparties. In particular, the different characteristics of retail versus corporate
deposits are well understood. Retail deposits are known as one of the most stable sources of
funding for institutions, with various degrees of stability23, including in a downturn. They are listed
as a separate category in the ASF template (ASF from retail deposits – rows 2.2 to 2.2.0.3). The
standard ASF factors for stable retail deposits of 95%, 95% and 100% for the three different
maturity buckets (<6months, 6months to 1year and >1year), respectively, versus the 50%, 50%,
100% for ‘other corporate non-financial liabilities’, shows the perceived difference in stability of
the two deposit types. Other counterparty types (such as financial), have even lower ASF factors
(eg 0%).
Option 16a: Align FINREP templates F 04.03.1; F 04.04.1; F 07.01; F 12.01; F 18.00 with the IFRS 9
requirements in the context of POCIs
23
EBA Guidelines (2013) establish three types of retail deposit buckets to which different outflow rates apply: Guidelines
on retail deposits subject to different outflows for purposes of liquidity reporting under Regulation (EU) No 575/2013, on
prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (Capital
Requirements Regulation – CRR)
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Option 16b: Do not align FINREP templates F 04.03.1; F 04.04.1; F 07.01; F 12.01; F 18.00 with the
IFRS 9 requirements in the context of POCIs
IFRS 9 has introduced an expected credit loss (ECLs) framework for the recognition of impairment.
Under this framework specific rules have been also established for the calculation of ECLs for
(POCI).
The current version of FINREP templates F 04.03.1; F 04.04.1; F 07.01; F 12.01; F 18.00 include
POCIs’ gross carrying amounts and accumulated impairments as part of instruments at impairment
stages 2 or 3, as applicable. Given the specific rules applying to POCIs’ ECL calculation, this is not
consistent with the new IFRS9 accounting rules: To reflect the specific rules applying to POCIs, the
latter should also be listed in a separate column as part of the reporting templates. It has therefore
been assessed that Option 16a is the preferred option, and it is proposed to align FINREP templates
F 04.03.1; F 04.04.1; F 07.01; F 12.01; F 18.00 with IFRS 9 requirements. Separate columns are
proposed to be included in the templates, showing gross carrying amounts and accumulated
impairments for POCIs, outside the impairment stages 24. This implies more granular data to be
reported by institutions, however, the additional columns are assessed as crucial to fully reflect the
IFRS 9 requirements in the reporting templates. In addition, institutions should have the more
granular information readily available, since the split-up is required for their internal ECL
calculations.
Option 17a: Add a new column on allowances for performing exposures past due for more than
30 days in F 18.00
Option 17b: Do not add additional columns on allowances for performing exposures past due for
more than 30 days in F 18.00
Under the IFRS 9 requirements, assets move from Stage 1 to Stage 2 when there is a significant
increase in credit risk. Usually, this occurs before there is any evidence of impairment or before a
default occurs. Moving assets from Stage 1 to Stage 2 (and as a result recognising lifetime ECLs),
should be based also on forward-looking information, in addition to past due information. If no
forward-looking information is available, a rebuttable presumption is in place that assets should be
moved from Stage 1 to Stage 2 (i.e. credit risk has increased significantly) no later than when
contractual payments are more than 30 days past due. This can be rebutted in case of evidence
that despite the past due status, there is no significant increase in credit risk. The movement from
Stage 1 to Stage 2 implies the passage from the recognition of 12-month expected credit losses to
the recognition of a full lifetime expected credit losses in the financial statements. For this reason,
it is important for supervisors to monitor how institutions are following these IFRS 9 requirements.
Under the current reporting framework V 2.9, the information on allowances for performing
exposures past due for more than 30 days is only reported by significant institutions. Since all
24
This will also have implications for the corresponding disclosure templates.
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institutions follow IFRS 9, this implies that supervisors lack some information that is useful in the
context of monitoring IFRS 9 post-implementation initiatives. Therefore, it has been assessed that
an additional column, reflecting impairments >30days past due, should be added and Option 17a
has been identified as the preferred option.
Option 18a: Include information on financial guarantees received in the form of credit derivatives
on non-performing loans and advances in template F 13.01
Option 18b: Include information on financial guarantees received in the form of credit derivatives
on non-performing loans and advances in template F 18.00
Given EBA’s new mandates on developing an extensive disclosure framework under CRR2, it is
important to ensure that the reporting framework is aligned as far as possible to ensure consistency
and efficiency and minimise the reporting and disclosure costs for institutions. Following new
disclosure requirements on information on financial guarantees received in the form of credit
derivatives on non-performing loans and advances, it has been chosen as the preferred option to
include this into template F 13.01, as an additional sub-column under the last column ‘Financial
guarantees received’ and a new sub-row on non-performing loans and advances. The alternative of
including the information in template F 18.00 instead has been assessed as sub-optimal, as it would
stretch the complexity of the latter template. F 18.00 includes a lot more granular information on
asset classes and as such would require substantially more information to be reported when further
splitting up the financial guarantees received.
D. Conclusion
Amendments to the reporting templates discussed above are necessary in order to enable
institutions to comply with the forthcoming CRR2 and the new Backstop Regulation and for
competent authorities to monitor the new and amended requirements.
The templates try to establish and maintain a uniform reporting system on the new regulatory
requirements, whilst at the same time accommodating as much simplicity and as little changes for
institutions as possible. The templates hence should achieve the goal of maximum consistency of
monitoring, reporting and transparency, with as little extra effort and costs as possible on
institutions.
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Question 2: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
Question 3: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
Question 4: The definitions of NPEs and Forbearance are now included in the CRR. So, FINREP
instructions on templates 18 and 19 have been reviewed, wherever appropriate, to refer to the
CRR. The review of the instructions takes into account that the basis for reporting in FINREP are the
accounting values and consistency across FINREP templates have to be kept. In addition, the
request of information of NPEs and Forbearance in FINREP is relevant for supervisory purposes
other than monitoring the prudential backstop calculation.
Do respondents agree with the review of instructions on the definitions of NPEs and Forbearance?
Question 5: The template F39 requests information on the stock of NPEs and related loss
allowances/provisions broken-down by the same time buckets as introduced in Article 47c of the
CRR and used in the new NPE LC templates of COREP as well. These data allow supervisors to
monitor institutions’ NPE coverage strategies more effectively and capture their risk profiles more
accurately. They complement, from an accounting perspective, the information provided in COREP
on prudential backstop calculation.
Which benefit and challenges with regard to the compilation and reporting of this information do
you envisage?
Question 6: Are the instructions and templates C35.01 to C35.03 clear to the respondents?
Question 7: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
Question 8: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
Question 9: Do respondents consider that the new proposed supervisory reporting templates
reflect correctly the disclosure requirements, in particular new templates which introduced
considerable change? Given that the integration aims at improving consistency, including a
standardisation in formats and definitions, do respondents agree that this objective is achieved?
Question 10: Are the instructions and templates clear to the respondents?
Question 11: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
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Question 12: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
Question 13: The template C 34.08 contains information on the collateral used in derivatives and
SFTs transactions at fair value. It is relevant to understand, on one hand, the part of the collateral
that is either segregated or unsegregated and on the other hand, whether it is initial margin,
variation margin or the SFT security. Therefore, the unsegregated collateral have been split
between initial margin, variation margin and SFT security. However, the segregated collateral has
not been split as it is considered that all segregated collateral is initial margin.
Do respondents agree that the segregated collateral is only initial margin? I.e. variation margin and
the STF security are only unsegregated collateral?
Question 14: The template C 34.06 provides information on the 20 counterparties with higher
counterparty credit risk exposure, including CCPs. The template should be provided by all institution
with counterparty credit risk on quarterly frequency.
Question 14.1: If further proportionality would introduced for this templates, would a threshold be
an appropriate way? If yes, which thresholds would respondents recommend to distinguish
between institutions that should report on quarterly basis and those that should report with lower
frequency? Should it be based on the size of the reporting institution, the size of the derivative
business, the total amount of CCR exposure or something else?
Question 14.2: Would a semi-annual frequency for small and non-complex institutions be adequate
to capture the volatility of these exposures?
Question 15: Do respondents consider that the supervisory reporting templates reflect correctly
the disclosure requirements, in particular new templates which introduced considerable change?
Given that the integration aims at improving consistency, including a standardisation in formats
and definitions, do respondents agree that this objective is achieved?
Question 16: Are the instructions and templates clear to the respondents?
Question 17: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
Question 18: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
Question 19: Article 429a(1)(d) and (e) of the CRR states that ”1.By way of derogation from Article
429(4), an institution may exclude any of the following exposures from its total exposure measure:
(d) where the institution is a public development credit institution, the exposures arising from
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assets that constitute claims on central governments, regional governments, local authorities or
public sector entities in relation to public sector investments and promotional loans; (e) where the
institution is not a public development credit institution, the parts of exposures arising from
passing-through promotional loans to other credit institutions”.
Question 19.1: Are the structures presented in Section 5.1.2 complete? If not, could respondents
provide detailed information on other structures in which a credit institution may have exposures
exempted in accordance with Article 429a(1)(d) or (e) of the CRR?
Question 19. 2: Do the proposed amendments provide for an adequate reporting on exposures of
credit institutions that are involved in these structures?
Question 20: Regarding the proposals to include averaging for some components of the leverage
ratio in accordance with Article 430(2) and (7) of the CRR, to develop the standards the EBA shall
take into account the how susceptible a component is to significant temporary reductions in
transaction volumes that could result in an underrepresentation of the risk of excessive leverage at
the reporting reference date.
Question 20.3: What leverage ratio components do respondent consider most and least
susceptible to temporary reductions in transaction volumes?
Question 21: Regarding the clarification of the reporting in template C43.00 on whether the
breakdown of the RWA should take into account potential substitution effects due to credit risk
mitigation, i.e. whether to perform the exposure type categorisation of RWEA by original obligor or
guarantor, and bearing in mind that in any case the RWEA reported in C 43.00 is after the RWEA
reducing effect of CRM, the respondents are requested to provide the information below
cconsidering the importance of consistency as well as reporting costs.
Question 21.1: Would respondents agree to align the information reported by requiring the RWEA
in this template without taking into account potential substitution effects due to credit risk
mitigation?
Question 21.2: Would respondents strong reasons based on costs to prefer instead the reporting
of both values, the RWA as well as the leverage ratio exposure, after substitution effects? What
would be the reasons?
Question 22: Are the instructions and templates clear to the respondents?
Question 23: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
Question 24: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
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Question 25: Are the instructions and templates clear to the respondents?
Question 26: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
Question 27: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
5.4.7 NSFR
Question 28: Paragraph 4 of Article 428d in the CRR2 states: “all derivative contracts referred to in
points (a) to (e) of paragraph 2 of Annex II that involve a full exchange of principal amounts on the
same date shall be calculated on a net basis across currencies, including for the purpose of reporting
in a currency that is subject to a separate reporting in accordance with Article 415(2), even where
those transactions are not included in the same netting set that fulfils the requirements set out in
Article 429c(1).”
Reporting by currency subject to separate reporting is required to be made on a net basis across
different netting sets. This might envisage a situation of derivatives across various counterparties
with different settlement currencies. There is a need to provide further instructions on which
specific currency subject to separate reporting report should capture the net value in these cases.
The implication is that the CRR2 requires consistency between ASF and RSF by currency subject to
separate reporting on which specific requirements can be set by CAs.
It is proposed to look at each netting set and calculate the fair value for each of them in its
settlement currency. For all netting sets with matching settlement currencies a net amount shall
be calculated in accordance with Article 428k(3) and 428ag(3), and reported in the relevant
currency subject to separate reporting.
Do respondents agree with this proposal? Would respondents consider it more adequate to look
at all payables and receivables related to derivatives and calculate a net amount?
Question 29: Do respondents consider that the “NSFR calculation tool” appropriately translates the
use of the different templates for informative purposes?
Question 30: Are the instructions and templates clear to the respondents?
Question 31: Do the respondents identify any discrepancies between these templates and
instructions and the calculation of the requirements set out in the underlying regulation?
Question 32: Do the respondents agree that the amended ITS fits the purpose of the underlying
regulation?
5.4.8 FINREP
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Question 33: Under Appendix A (IFRS 9), purchased or originated financial assets (POCIs)
correspond to purchased or originated financial assets that are credit-impaired on initial
recognition.
IFRS 9 sets out specific rules to measure the expected credit losses (ECL) for POCIs, outside the
general approach to impairment by Stage. In order to have a presentation of POCIs more consistent
with their measurement criteria, in the following templates F04.03.1; F04.04.1; F07.01; F12.01;
F18.00, POCIs are included in separate columns outside the Impairment Stages.
In the template F18, POCIs are also split between non-performing and performing, to take into
account any cases where, after the initial recognition, POCIs do not meet the definition of “credit-
impaired” of Appendix A (IFRS 9) anymore.
Question 33.1: Do respondents agree with the separate presentation of POCIs outside the IFRS 9
Impairment stages?
Question 33.2: Are the criteria to distinguish between “non-performing” and “performing” POCIs
clear? Which challenges with regard to the practical application of these criteria do you envisage?
Question 34: The information on cash balances at central banks and other demand deposits has
been included in template F12.01. Although the amount of impairment for cash balances at central
banks and other demand deposits should not be relevant in general, these assets are subject to
impairment as the other financial assets included in the accounting portfolios of “financial assets
at cost or amortized cost” and “financial assets through equity subject to impairment or at fair value
through other comprehensive income”. The inclusion of these data is also consistent with data
reported in templates F18 and F19.
Question 34.1: Which challenges with regard to reporting of this information do respondents
envisage?
Question 34.2: Do you see any inconsistencies between this data and the data collected in other
FINREP templates?
Question 35: In template F12.02, additional columns have been added to report the direct transfers
between Stage 1 and Stage 3, without considering any intermediate passage through Stage 2. This
information is useful in the context of monitoring IFRS 9 post-implementation initiatives and
supervisory activities.
Question 36: In template F18.00, the information on loss allowances for more than 30 days-past-
due exposures has been added. This information is already reported in template F23.04 by
institutions which fulfil both of the conditions referred to in points (i) and (ii) of Article 9(2)(h) of
the current ITS on reporting. Since this information is relevant for monitoring IFRS 9 post-
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implementation initiatives and supervisory activities, it has been included in template F18.00 for all
institutions, although it may create some overlaps with F23.04.
Question 37: Are the instructions and templates clear to the respondents?
Question 38: Do respondents agree with the proposal to harmonise templates and instructions
with regard to the reporting of the information of LEI codes?
Question 39: The integration between disclosure and reporting aims at improving consistency,
including a standardisation in formats and definitions. Do respondents agree that this objective is
achieved?
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