Prudent valuation - new template C.32.01

At the analysis of the new template C.32.01 which must be filled starting from reporting date 31.12.2018 we found some constellations which we cannot allocate so easily in the new form. Here we would ask you for guidance. 1. Eurex-Netting Here derivatives of different hedging relation and valuation categories are netted and the netting result is finally shown in only one finrep position which is derivatives – hedge accounting (in the template rows 1.1.9 or 1.2.4). Here are also some derivatives included for which the hedging relation should be shown in column 030 exactly matching. The reason is that the other deal of the hedging relation which is not part of the netting agreement is also shown here. At the rows 1.1.9 or 1.2.4 the column exactly matching is, however, shown greyed out. If we – for instance – evade to column 040 other, then column exactly matching does no longer show the same total on the asset side and the liabilities side what – we suppose – would contradict to the expectations of EBA. How can we show this constellation properly in the template? 2. Portfolio Fair Value Hedge Accounting (rows 1.1.10 and 1.2.5 in the template) We regard the bookings in this balance sheet positions also as a part of hedge accounting and thus cannot understand why in these rows 1.1.10 and 1.2.5 column 040 hedge accounting is shown greyed out. Where can we show in the template the deduction items which we calculate for prudent valuation at portfolio fair value hedge accounting? 3. Change of algebraic sign at some trades There are cases where the total book value is lower than the hedge adjustment included in the book value. This means that after elimination of the hedge adjustment in column 030 or 040 the algebraic sign of the book value changes. In the result column 080 the problem is solved by showing the absolute value for the calculation basis for the prudent valuation of every deal. So undesirable netting effects inside this column are avoided. At the deduction rows 030 – 060 it is not so easily possible to show a transparent calculation. Example: Deal 1 Book value 80 Hedge Adjustment 100 Result 20 (absolute value) Deal 2 Book value 100 Hedge Adjustment 90 Result 10 (absolute value) Then the cells in template show the following figures: Book value 180 Hedge adjustment 190 Result 30 (absolute value) This is correctly calculated, but not transparent and the validation rules are not complied with.

We apply the simplified approach for prudent valuation. Starting from reporting date 31.12.2018 we will have to populate the new form C.32.01. Since only positive values are allowed and the result column is an exact difference between the original book value and the deduction items that are allowed in the RTS on prudent valuation we have problems with some constellations where the algebraic sign changes or where we would Input figures in cells which are shown greyed out.