EBA · 2021_5736 Final Q&A

Validation rule v7378 - securitization templates C 13.01 and C 14.01

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
99
Topic
Supervisory reporting - COREP (incl. IP Losses)
Submitted by
Other
Submitted
2021-02-12
Answered
2021-09-10
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Question

Should validation rule v7378 be triggered in case you have 1 entity which leads to a significant risk transfer (SRT) and 1 entity that is not leading to a SRT?

Background

We report 2 entities in template C 14.01 however only 1 in template C 13.01. We refer to the general remarks paragraph 100 of Annex II from the ITS stating "100.In case the institution acts as originator, the information in this template shall be required for all securitisations for which a significant risk transfer is recognised. In case the institution acts as investor, all exposures shall be reported." The validation rule is implemented to check whether the total exposure in C 14.01 column 0411 matches with C 13.01 row 010 column 180. This will not match in case you report 2 entities in C 14.01 (1 entity with significant risk transfer (SRT) and 1 entity without SRT) and compare it to the exposure of the single entity with SRT. Moreover, validation rule v7378 seems inconsistent because the two templates do not cover the same scope. Indeed, according to the Annex II of the ITS on Supervisory Reporting the CR SEC template gathers information on securitization held in the banking book, while the SEC Details 2 held gathers information held in both the banking book and the trading book.

Answer

EBA validation rule v7378_m states that the sum of the exposure values reported in column 411 of template C 14.01 on a transaction basis on all securitisation positions held by the institution shall be equal to the total exposure value of securitisation positions calculated in accordance with Article 248 CRR reported in column 180 of template C 13.01. According to section 3.7.1 institutions shall only report data in template C 13.01 on securitisations that are held in the banking book. Since, according to section 3.8.2, reporting in column 0411 of C 14.01 is not applicable to securitization positions in the trading book, validation rule v7378_m is correct.

Original source: European Banking Authority, Q&A ID 2021_5736

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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