EBA · 2014_1378 Final Q&A

Missing Entity code

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
99, para. 2
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Submitted by
Credit institution
Submitted
2014-07-18
Answered
2016-06-10
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Question

What should be reported in column 020 in table F 40.01 Annex III , if entity code is missing for an entity? Should the cell be left empty, if an LEI code is existing for the entity?

Background

The entity code should be a valid MFI code from the ECB MFI list. However, MFI codes could be missing for some of our consolidated subsidiaries as they do not fall under the definition of an MFI as they do not perform banking activities. Also, the corresponding National Central Bank has not allocated them a national ID code. We propose to leave the column empty for those entities where the code is missing, provided a valid LEI code is reported in column 010 as the latter would meet the identification needs.

Answer

According to the definitions of the DPM, column 020 of Template F 40.01 of Annex III of Regulation (EU) No 680/2014 - ITS on Supervisory Reporting of institutions (ITS) is defined as "key value". The "key value" is a unique row identifier and must be reported. If only the LEI code is available, it should be reported in columns 010 (LEI code) and 020 (Entity code). There may be cases where a group entity does not have an LEI code, either because the global LEI system is not yet fully operational or due to the entity not being a party to a financial transaction. As noted in EBA Q&A 2013_333, when the LEI (or pre-LEI) code of the investee is missing and cannot be used as a substitute for a missing MFI code in {F 40.01, c020}, the data point should be populated with an alternative code used to identify the investee (e.g. national identification code).

Original source: European Banking Authority, Q&A ID 2014_1378

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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