EBA · 2015_1722 Final Q&A

Asset Encumbrance Reporting for firms with Accounting Reference Date other than 31 December

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
100
Topic
Supervisory reporting - Asset Encumbrance
Submitted by
Competent authority
Submitted
2015-01-15
Answered
2017-08-04
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

Article 2(3) of the ITS on Supervisory Reporting allows the uniform reporting and remittance dates for reporting financial information (i.e. FINREP) to be adjusted where institutions are permitted by national laws to report their financial information based on their accounting year-end which deviates from the calendar year (this was also clarified in the response to Q&A 147). The supervisory reporting templates on Asset Encumbrance follow, from a methodological point of view, FINREP and the current ITS also includes some cross validation checks between certain data points in FINREP and the AE templates. In this regard, can the same flexibility with the reporting and remittance dates (in Article 2(3) of the ITS on Supervisory Reporting) provided to institutions that have an accounting year-end which deviates from the calendar year in terms of reporting FINREP also be extended to the reporting of the Asset Encumbrance templates?

Background

Some banks which report their financial information based on their accounting year-end which deviates from the calendar year have queried whether the same flexibility permitted under Article 2(3) of the ITS on Supervisory Reporting in terms of the reporting and remittance dates for FINREP should also be extended to the Asset Encumbrance templates. The asset encumbrance templates are based on accounting values (carrying amounts) in order to ensure the possibility of reconciling the reported figures with the balance sheet items (FINREP). In this regard, it makes sense that the same reporting and remittance dates applied to FINREP returns are also applied to the Asset Encumbrance templates

Answer

According to Article 2(3) of Regulation (EU) No 680/2014 (ITS on Supervisory Reporting), where reporting institutions are permitted by national laws to report their financial information based on their accounting year end which does not coincide with the calendar year, they may adjust their reporting reference dates accordingly. This discretion to adjust the reporting reference dates is only available for financial information (FINREP, Annexes III, IV and V) and, thus, shall not be applied to other parts of the ITS on Supervisory Reporting such as own funds requirements (COREP, Annexes I and II) or assets encumbrance (Annexes XVI and XVII).

Original source: European Banking Authority, Q&A ID 2015_1722

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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