Inconsistencies in FINREP validation rules for Allowances and provisions for impaired debt instruments, defaulted guarantees and defaulted commitments (F31.01)

The FINREP framework follows a sign convention based on a credit/debit convention which is explained in Annex V, Part 1 paragraphs 9 and 10 of Regulation (EU) No 680/2014 - ITS on Supervisory reporting. The use of sign convention is also clarified in Q&A 2034. F31.01 row 130 (Annex III, IV of Regulation (EU) No 680/2014) should cover "Accumulated impairment, accumulated changes in fair value due to credit risk and provisions on non-performing exposures". Accumulated impairments are reported with a negative sign, provisions are reported with a positive sign and fair value changes due to credit risk can have both signs. However, since row 130 covers only non-performing exposures it is not expected that accumulated changes in fair value due to credit risk would be positive (accumulated gains). The reporting should be done in the following way to allow right sign convention but avoid netting of provisions (which have a positive sign) against impairments (which have a negative sign). On non-performing exposures: Accumulated impairments (negative sign) + provisions x (-1) (positive sign changed to negative) + accumulated changes in fair value due to credit risk (gains are positive, losses negative) = Accumulated impairment, accumulated changes in fair value due to credit risk and provisions on non-performing exposures The result will have either negative or positive sign depending on amount of positive fair value changes due to credit risk. For exampleAccumulated impairments of -150Provisions of 35Accumulated changes in fair value due to credit risk of -45 -150 +(35*(-1)) - 45 = -150 13 35 13 45 = -230 to be reported in F31.01 row 130 Validation rule v3974_s has been deactivated and will be amended to exclude row 130.