EBA · 2023_6896 Rejected question

Scope of Template 2 restricted to NFCs?

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
449a
Topic
Transparency and Pillar 3
Submitted by
Credit institution
Submitted
2023-09-27

Question

According to the Annex II (Instructions for disclosure of ESG risks) with the regard to Template 2: Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral: The Template should show the gross carrying amount, as referred to in Part 1 of Annex V to Implementing Regulation (EU) 2021/451, of loans collateralised with commercial and residential immovable property and of repossessed real estate collaterals. We do not see an explicit restriction to non-financial corporates as in Template 5, for example (Definition in Template 5: … Institutions shall disclose the gross carrying amount as defined in Part 1 of Annex V to Implementing Regulation (EU) 2021/451 of those exposures towards non-financial corporates (including loans and advances, debt securities and equity instruments), classified under the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading and held for sale assets.…) The “Annotated Table Layout 330-P1-ESG 3.3.xlsx” of EBA Reporting framework 3.3 in templates D 02.00.a and D 02.00.b restricts the scope of Template 2 to non-financial corporations with the Counterparty sector field. In our opinion, the restriction is not clearly given by Regulation (EU) 2022/2453 so we ask for clarification of the fact. Is the assumption correct that in case the restriction to non-financial corporations is given in Template 2, the gross carrying amount of Template 2 column a row 0010 Total EU area and Total non-EU area 0060 is corresponding to Template 5 column b row 0100 Loans collateralised by residential immovable property, 0110 Loans collateralised by commercial immovable property and 0120 Repossessed collaterals?

Background

According to the Annex II (Instructions for disclosure of ESG risks) with the regard to Template 2: Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral: The Template should show the gross carrying amount, as referred to in Part 1 of Annex V to Implementing Regulation (EU) 2021/451, of loans collateralised with commercial and residential immovable property and of repossessed real estate collaterals. We do not see an explicit restriction to non-financial corporates as in Template 5, for example (Definition in Template 5: … Institutions shall disclose the gross carrying amount as defined in Part 1 of Annex V to Implementing Regulation (EU) 2021/451 of those exposures towards non-financial corporates (including loans and advances, debt securities and equity instruments), classified under the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading and held for sale assets.…)   The “Annotated Table Layout 330-P1-ESG 3.3.xlsx” of EBA Reporting framework 3.3 in templates D 02.00.a and D 02.00.b restricts the scope of Template 2 to non-financial corporations with the Counterparty sector field.   In our opinion, the restriction is not clearly given by Regulation (EU) 2022/2453 so we ask for clarification of the fact.   Is the assumption correct that in case the restriction to non-financial corporations is given in Template 2, the gross carrying amount of Template 2 column a row 0010 Total EU area and Total non-EU area 0060 is corresponding to Template 5 column b row 0100 Loans collateralised by residential immovable property, 0110 Loans collateralised by commercial immovable property and 0120 Repossessed collaterals?
No answer published yet.

Original source: European Banking Authority, Q&A ID 2023_6896

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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