EBA · 2024_7162 Final Q&A

Calculation of the net open position for capital requirements for structural FX risk

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
352, para. 2
Topic
Market risk
Submitted by
Credit institution
Submitted
2024-08-02
Answered
2024-11-15
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

In the context of article 352.2, in relation with the consolidated capital calculation for FX risk,  the historical cost at solo basis must be taking into account or not?

Background

In the case of an institution having investments in a subsidiary which is considered at historical cost at solo basis, these investments are not part of the consolidated balance sheet as far as they disappear in the process of consolidation. In the consolidated balance sheet, the investment in the subsidiary is considered as assets and liabilities that only arise during the consolidation process.  Paragraph 104 of EBA Guidelines on the treatment of structural FX under Article 352(2) of Regulation (EU) No 575/2013 (CRR) makes reference to this issue “This ad hoc treatment is of particular relevance in the context of the structural FX provision applied at the solo level. Indeed, there is the presumption that non-monetary items at historical cost generating an FX risk would mainly be investments in subsidiaries denominated in a foreign currency (i.e. in general, the reporting currency of the subsidiary). Such investments are not part of the consolidated balance sheet, as the investments in the subsidiary (which are assets in the institution owning the subsidiary) net with the capital (i.e. liabilities side) of the subsidiary itself during the consolidation process. As a result, the above-mentioned treatment for non-monetary items at historical cost is deemed to have a limited impact in the context of the structural FX provision at the consolidated level.” And it seems to indicate that the historical cost of the investment has not to be used.

Answer

The treatment of investments should be consistent with the level of calculation: consolidated or solo basis. When calculating FX risk at solo level, the institution have to consider the investment that is at historical cost for FX risk purposes. The FX risk stemming from this item may then be excluded from the net open position in accordance with the provisions set out in the GLs for structural FX. When an institution uses the alternative standardised approach or the alternative internal model approach referred to in Article 325(3)(a)-(b) CRR, institutions shall use the provision set out in Article 1(4)-(5) and Article 3(6) of COMMISSION DELEGATED REGULATION (EU) 2023/1577 as regards to the calculation of the FX risk where the investment is an item meeting the conditions referred to in those articles. When calculating FX risk at consolidated level, where an investment is fully consolidated, the investment itself should not be considered. The institution should however consider the assets and liabilities stemming from the subsidiary during the consolidation process in the FX risk calculation. Depending on whether the institution has the permission referred to in Article 325b CRR, those positions stemming from the subsidiary may be offset with the positions held by the parent institution.

Original source: European Banking Authority, Q&A ID 2024_7162

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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