Row 0820 of C 04.00

Row 0820 of C 04.00 - Own funds requirements related to Pillar II adjustments states that if a competent authority decides that an institution must calculate additional own funds requirements for Pillar II reasons, those additional own funds requirements shall be reported in this row. Two approaches could be considered: This row shall only be reported when Pillar II adjustments have been established as an amount instead of a ratio.  This row shall always be reported: If Pillar II adjustments have been set as a ratio the amount to be reported is: P2R*RWA. If Pillar II adjustments have been set as an amount that figure shall be reported in row 0820 of C 04.00.  Therefore, instructions do not establish which additional own funds requirements shall be reported.  Thus, which approach shall be followed to report row 0820 of C 04.00?

As it has been mentioned in “Question” section instructions of row 0820 of C 04.00 do not provide enough clarity of what is expected in this row . There are two possible situations: Competent Authority has established a P2R equal to 1 % to an institution which reports 10.000 € of RWAs.  Row 0820 = Blank Row 0820 = 1 % * 10.000 = 100 Competent Authority has established a P2R equal to 100 €  Row 0820 = 100 This issue was addressed in Q&A 2016_2699 although is archived row 0 0820 instructions of C 04.00 have not been amended. Therefore, it could be understood that the following paragraph of that Q&A still applies to C 04.00:  “in case the Competent Authority requires the institution : 1. to meet specific target ratios according to Article 104 (2) CRD, these target ratios should be reported in C 03.00 rows 080, 100 and 120 and nothing should be reported in C 04.00, row 820; 2. to calculate additional own funds requirements for Pillar II pursuant to Article 104 (2) CRD, this amount should be included in the solvency ratios reported in C 03.00 rows 070, 090, 110 and, furthermore, included in row 820” As an internal comment: We have seen institutions which Pillar II adjustments have been set as a ratio that follow two different approaches related to row 0820 of C 04.00: Row 0820 = Blank Row 0820 = P2R*RWA.