EBA · 2017_3175 Final Q&A

Annex VI, template C 108.00, Definition of P&L

Regulation
Directive 2013/36/EU (CRD)
Article
78, para. 2
Topic
Supervisory reporting - Supervisory Benchmarking
Submitted by
Credit institution
Submitted
2017-02-22
Answered
2017-03-24
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

Is the definition of P&L, for template C108.00, (i) the P&L Vector generated using historically simulated daily market price/risk factor movements; ie. the underlying daily P&L distribution used to derive VaR; or (ii) instead, the actual P&L (adjusted for Theta, settled cash flows, etc)?

Background

Template C 108.00 states that "Institutions that calculate VaR using Historical Simulation shall fill the one-year data series with the portfolio valuation change (i.e. daily P&L) produced on each business day (i.e. by comparing the end-of-day valuation on each business day reported in column 10 with the end-of-day valuation on the previous business day)." Last year, our supervisors had specifically requested for the latter given the above wording can be interpreted as the actual P&L from MtM changes. However, the actual P&L poses the following problems: it is not available for dates prior to the booking date (13 October 2017), and so, a full year's history is not available; it is more suitable for backtesting, and so, does not validate the computation of the VaR on 17 February 2017 (as submitted in template C107.02), if this is the EBA's reasoning; and if it is linked to backtesting, why it would be restricted to just institutions using Historical Simulation, given all institutions must perform backtesting.

Answer

The instructions on column 0 020 (“Daily P&L”) of template C 108.00 of Annex VII to  the Draft Regulation (EU) 2016/2070 ITS on Supervisory Reporting for Institutions for benchmarking the internal approaches ( draft ITS on Supervisory Benchmarking) for the 2017-exercise as provided in Annex VI of that ITS foresee that: ‘Institutions that calculate VaR using H h istorical S s imulation shall fill the full length historic series used by the institution, with a minimum of one-year data series with the portfolio valuation change (i.e. daily P&L) produced on each business day (i.e. by comparing the end-of-day valuation on each business day reported in column 010 with the end-of-day valuation on the previous business day). In case a day is a bank holiday in the relevant jurisdiction, this cell shall be left blank (i.e. a zero P&L shall be reported only if there really was no change in the hypothetical value of the portfolio on a given business day). Figures shall be reported in units in the base currency of the portfolio. ’ This means that only banks that are using the Historical Simulation approach shall report this column and that they have to report the one-year daily P&L series used to derive regulatory VaR results. Disclaimer: The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal. The text of the Implementing Regulation may differ from the text of the draft ITS to which this Q&A refers.

Original source: European Banking Authority, Q&A ID 2017_3175

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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