FINREP Taxonomy 2.5 Templates 04.04/18.00.b Validations

In taxonomy 2.5, are validations v3049_m to v3076_m the correct way round? That is, should the “<=” sign be “>=”?

Taxonomy 2.5 includes a number of reactivated validations. In particular, validations v3049_m to v3076_m require, for each counterparty, that the provisions on non-performing exposures (template 18.00.b column 150) are less than or equal to the total specific provision for that counterparty on template 04.04 (columns 030 and 040). Annex V Part 2.161 states “Incurred but not reported losses shall be reported in accumulated impairment on performing exposures”. Therefore, such impairments cannot be included in column 150 of template 18.00.b. As impairment provisions on both templates are presented as negative balances, the validations require the impairments on non-performing exposures to be “more negative” (i.e. more impaired) than the total specific provision on template 04.04. Given that the “incurred but not reported losses” cannot be included in non-performing, and given that some collectively assessed specific provisions are included within performing, it does not seem possible to pass these validations. It is possible that the sign on these validations should be reversed?