Reporting of exposures with immovable property as collateral

A bank has its head office in one EU country and has a branch in Luxembourg. Both the head office and the branch are required to submit separately template C15. The Luxembourg branch submits in Luxembourg template C15 with the branch information only. According to Annex VII of the Commission Implementing Regulation (EU) No 680/2014. The exposures to be reported in template C15 relate to exposures whose collateral (immovable property) is used to reduce regulatory own fund requirements. The head office and the Luxembourg branch have some loans secured by immovable property in various countries. However, the immovable property is not used either at the head office or at the Luxembourg branch for reducing regulatory own fund requirements. Therefore, our understanding is that neither the head office nor the Luxembourg branch should report these exposures in C15 template. We would like to confirm this approach following the request of the national competent authority given that there are no separate capital requirements at the Luxembourg branch level.

Extract from ANNEX VII INSTRUCTIONS FOR THE REPORTING ON LOSSES STEMMING FROM LENDING COLLATERALISED BY IMMOVABLE PROPERTY 4. Reporting of exposures and losses 11. Exposures: All exposures that are treated according to Part Three, Title II of CRR and where the collateral is used to reduce own funds requirements, are reported in CR IP Losses. This also means that in case the risk mitigation effect of immovable property is only used for internal purposes (i.e. under Pillar 2) or for large exposures (see Part Four CRR), the exposures and losses concerned must not reported.