Reporting of the collateral and guarantees by loans and advances

Article 174 from Annex V mentions that where the ‘Maximum collateral/guarantee that can be considered’ exceeds the value of immovable property collateral, its remaining value shall be allocated to other collateral types and guarantees according to its quality, starting from the one with best quality. There are no details regarding the expectation of reporting for different types of collaterals used at the same time to cover different types of loan and advances if the amount of the collaterals is smaller than the total exposure covered (n:m relationships). It is not clear how the collateral should be split between the loans (if a particular order should be followed or an optimization model should be used) and if for immovable properties the prior liens are deducted from the property value before the maximum amount is calculated.  Example for F 13.01: Residential immovable property = 100.000 Prior lien on the property = 20.000 Financial guarantee received = 10.000 Loan 1 to a non-financial corporation = 70.000 Loan 2 to other financial corporation = 60.000 Both loans are covered by the immovable property and the financial guarantee. Position 0010/0010 F 13.01: 100.000 or 80.000 (after the prior lien is deducted) Position 0010/0050 F 13.01: 10.000 Which amounts are expected in rows 0010, 0020 and 0030, columns 0010/0050 from F 13.01?

The unclarity in the reporting of complex constellations of collaterals allows for different interpretations and cause differences in the reporting of the same situation by the reporting entities.