EBA · 2015_2388 Final Q&A

Clarification on Funding Plans significant currencies criteria

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
99
Topic
Supervisory reporting - Funding Plans
Submitted by
Competent authority
Submitted
2015-10-09
Answered
2016-07-29
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

What rule should be followed given the discrepancy between what the EBA Guideline establishes and the criteria given by the template GL on FP?

Background

The part "4.4.4 Technical options proposed" from the "Guidelines on harmonized definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2 indicates that "A reporting credit institution only has to complete this if it has significant business (greater or equal to 5% of either assets or liabilities) in the foreign currency. However, in the instructions of Annex I Templates for GL on FP, in section 2c, Structural Currency Mismatches states "Please provide a breakdown of your balance sheet by the three largest material currencies. Please note, we only expect firms to report a currency where it accounts for more than 5% of total liabilities, as per CRR Art 415 2 b).

Answer

Template P 02.06 of Annex I of EBA/GL/2014/04 (the GL) refers to structural currency mismatches based on a breakdown of the three largest material currencies. The instructions currently refer to Art. 415 (2) lit. b CRR but they should refer to Art. 415 (2) lit. a CRR. Institutions shall identify all material currencies, including reporting currency, based on the instructions provided in Annex I of the GL, i.e. based on the threshold for significant currencies in Article 415 (2) lit. a CRR which takes into account only the amount of liabilities, not of the assets. If the institution identifies only one or two significant currencies, only those shall be reported. Please see also Q&A 2015_2329 on reporting of reporting currency as material currency.

Original source: European Banking Authority, Q&A ID 2015_2388

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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