EBA · 2024_7038 Rejected question

Val rules_v12727_m_for template 7 GAR amount is not aligned with ITS

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
449a, para. N/A
Topic
Transparency and Pillar 3
Submitted by
Other
Submitted
2024-03-14
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Question

We believe the ITS instructions 2022/2453  are incorrect for Row 32 into ITS (EU) 2022/2453. NB =  equivalent row into DPM is 0320.

Background

Row 32 into ITS (EU) 2022/2453 / row 0320 in DPM: “ Total GAR assets: This row shall be equal to row 1 of this template.” While this validation rules indicates we must also sum the row 0310: v12727_m: {r0320} = {r0010} + {r0310}   Row 310 is for “ Collateral obtained by taking possession: residential and commercial immovable properties” and this type of assets must be part of the GAR numerator.   Validation rule v12728_m: {r0010} = {r0020} + {r0200} + {r0240} + {r0280}.  It means row 310 is not considered into row 0010. It seems logical because row 0010 title is “ Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation ”.  Collateral obtained by taking possession RRE/CRE cannot fit with the title of row 0010 because if the bank has taken possession of a collateral, it is not a loan anymore, it is a physical asset from the bank.
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Original source: European Banking Authority, Q&A ID 2024_7038

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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