Validation rules of templates F 24.01 and F 24.02 specifically EGDQ_0665, EGDG_0666, XBRL v8035_m and XBRL v8052_m. These validations impose that the closing figures of the prior financial year end should tally with the opening figures of the current reporting quarter without allowing for reclassifications or changes of the counterparties’ reporting criteria segregated in F 24.01 and F 24.02, namely collateral type, and SME criteria.

For accounts which do not have a change in non-performing status, how are changes in collateral and/or SME status of the counterparty are to be reported in F 24.01 and F 24.02, since validation rules of templates F 24.01 and F 24.02, specifically EGDQ_0665, EGDG_0666, XBRL v8035_m and XBRL v8052_m, cannot all be complied with simultaneously when such changes occur after the previous financial year end?

According to Annex V or Regulation EU No: 2021/451, templates F 24.01 and F 24.02 shall provide a reconciliation of the opening and closing balances / allowances of the stock of non-performing loans and advances. Inflows and outflows during the period to/from the non-performing category shall be reported.  According to validations issued by European Central Bank’s Expert Group on Data Quality, EGDQ_0665 and EGDQ_0666, the opening balances of templates F 24.01 and F 24.02, row 0010, of columns 0010, 0020, 0030, 0040, 0050, 0060 and 0070 of the current reporting quarter are to tally with the closing balances of row 0320 of the same template of the same column of the previous financial year end. These validations do not consider changes in collateral such as: removal, increase or substitution of residential or commercial immovable property or change of the SME status of the client during the financial year of the current reporting period in comparison to the end of the previous financial year. For accounts which do not have a change in the non-performing classification, if the change is reported as inflow/other due to other reasons under the related ‘of which’ column, XBRL v8035_m or XBRL v8052_m which require that the closing balances of F 24.01 and F 24.02 shall agree to the balance reported within F 18.00.A  and F 18.00.B will be triggered.  Moreover, various XBRL errors (for example v8038, v8039) would also be triggered since the ‘of which’ column will be reporting an amount which is greater than the amount reported in column ‘0040’. Based on the premise that inflows and outflows refer only to the movements to/from the non-performing category and do not consider the possibility of any change in the classification of a change in collateral, we cannot comply with the validation rules (v8038, v8039, v8036, v8052) and the EGDQ checks (EGDQ_0665 and EGDQ_0666). Having been guided by the reply to Q&A 2020_5613 where the EBA answer was that the opening balance should be adjusted to reflect the real situation at the reporting date, we have been advised by the local authority that EBA Q&A 2020_5613 reflects only the specific situation of a change in SME and not for a change in collateral.  Therefore, we seek guidance on how a change in collateral should be reported in F 24.01 and F 24.02.