Validations

The validation rule v2863_m {F 32.04.a, r140,c010} <= {F 09.02, r080,c010} is incorrect as per the background on this question. Please can the rule be deleted.

v2863_m {F 32.04.a, r140,c010} <= {F 09.02, r080,c010} is incorrect. In table F9.2 Loan commitments, financial guarantees and other commitments received, the notional amount of the financial guarantees received is capped to the extent of the loan outstanding as per ITS para 63: 'For financial guarantees received, the “maximum amount of the guarantee that can be considered” is the maximum amount the counterparty could have to pay if the guarantee is called on. In table F32.04 Sources of encumbrance the nominal amount of the financial guarantees reported should be the assets which have been encumbered against it. There are instances wherein the assets encumbered could be higher or lower compared to the loan outstanding. In such a situation the amount encumbered differs from the loan amount outstanding. Following are the situations wherein this rule will not work: Assuming bank has provided a committed line of US$100mn to a customer and US$50MN has been drawn against it. The bank in this situtation could have gone out and secured the guarantee on the entire facility of US$100Mn by pledging its assets. In such situation table 9.2 will report the guarantee received for US$50MN as it is capped to the extent of loan outstanding but in table 32.04 the amount of guarantee that will be reported will be US$100Mn as the assets to that extent are encumbered against it and cannot be freely withdrawn. In this case amount reported in table 32.04 is higher than amount reported in table 9.2. There could also be another instance wherein financial guarantees are received without encumbering the bank assets and in such instances table 32.04 will report nil but table 9.2 will report the guarantee amount to the extent of loan amount outstanding. Hence the amount reported in 32.04 is lower than amount reported in table 9.2. In summary the financial guarantees reported in table F9.2 is capped to the extent of loan outstanding and in table F32.04 the full amount of the guarantees against which assets have been encumbered is required to be reported and if no assets are encumbered then no amount should be reported.