EBA · 2022_6638 Rejected question

NSFR - presentation operational deposits

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
430
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Submitted by
Credit institution
Submitted
2022-11-23

Question

Is the instruction in Annex 13 to item 2.6 (C 84.00, r0180, c0030) correct?

Background

The instruction in Annex 13 to item 2.6 of template 84 {C 84.00, r0180, c0030} prescribes that the amount to be reported in this field should match the amount of item 2.5 of reporting template C 81.00 and that the amount of item 2.5.3.1 of reporting template C 81.00 should be excluded of this. Based on the Taxonomy, {C 84.00, r0180, c0030} should equal {C 81.00, r0230, c0100} because both fields refer to the exact same DataPointID (458912). This is not a published validation rule, but given the fact that both fields refer to the same DataPointID, per definition, those fields should be equal. Reporting according to the instructions of Annex 13, in case there are operational deposits to financial customers, automatically leads to an error compared to the Taxonomy. Excluding the amount of operational deposits (conform instructions) leads to a lower amount on {C 84.00, r0180, c0030} compared to the amount on {C 81.00, r0230, c0100}. Therefore, the instruction of Annex 13 seems inconsistent with the Taxonomy. We ask the EBA to clarify on this matter and confirm whether the instruction in Annex 13 is correct or not.   This Q&A has been rejected in 2021 as the EBA was already aware of this problem and promised to solve this in reporting framework 3.2. However the changes have not been implemented in DPM 3.2 and banks are now applying various manual workarounds to report template C84 adequately.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2022_6638

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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