Clarification on reporting of “Total Assets” within C40.00 {0410;0010}, as defined in Annex XI.

Annex XI defines {C40.00, r0410, c0010} as “the total assets following the scope used in the published financial statements.” Having regard to the meaning of the word “published” used within this context, please confirm whether the total assets to be reported in C 40.oo must necessarily be equivalent to the total assets disclosed in the latest interim or year-end published financial statements. If in the affirmative, this would imply that, for institutions with only semi-annual and year-end publication dates (as opposed to quarterly publications), {C 40.00, r0410, c0010} shall not be updated within two quarters during a calendar year, given that such figure would be held constant as per latest publication. If this treatment is confirmed, our question further extends to the intended reporting of constituent rows, such as C 40.00 r0010, c0010} and {C 40.00, r0090, c0010}. We understand that the scope of reporting shall be consistent across the entire template, therefore for such rows, we would like to confirm whether they shall also be kept constant as per latest published financial statements, given the lack of instruction to these specific rows.

This question arises in the context of EBA validation rule v10264, where “the accounting value of total assets ({C40.00.a,r0410,c0010}) should be equal to the accounting value of total assets in FINREP ({F17.01,r0370,c0010}”. In view that the Bank publishes its financial statements in June and December, a reconciliation between COREP_LR and FINREP F17.01 is only applicable for semi-annual and annual reference periods [i.e. June and December].  This in view that, whereas the reportable amount in FINREP shall always reflect the quarter-end position (whether or not such amounts are subsequently disclosed within published financial statements); in C40, for institutions which do not publish financial statements on a quarterly basis, the Annex XI instruction can be interpreted to mean that the reported figures shall be held constant as per latest published figures. In turn, for institutions with semi-annual and annual publication dates, the reported total assets in C40 for two out of four quarters within a calendar year would remain constant as per the reported position within the latest published financial statements.  To this end, based on such interpretation, EBA_v10264 cannot be satisfied for the March and September reference dates.