MREL-REPORTING OF THE IMPACT OF GENERAL PRIOR PERMISSION

With regard to the unused amounts of the general prior permission which are to be deducted from the MREL capacity from the moment the authorization is granted by the authority, in terms of MREL-TLAC reporting, the Bank would like to have a confirmation of its interpretation of the instructions on how to report the unused part of the GPP plafond in M01.00 (ANNEX II REPORTING ON THE MINIMUM REQUIREMENT FOR OWN FUNDS AND ELIGIBLE LIABILITIES) .

The Bank would like to have a confirmation of its interpretation of the relevant instructions on how to report the unused part of the GPP plafond in M01.00.  By a way of example, considering the following data: General Prior Permission plafond granted : 200 Unused Plafond : 50 MREL capacity : 1.000 Other Bailinable instruments : 3.000, of which 1.500 with Residual maturity of < 1 year 700 with Residual maturity of >= 1 year and < 2 years 800 with Residual maturity of >= 2 years In accordance with the Bank interpretation of the relevant reporting instructions, the Bank would deduct the Unused amounts of General prior permission in row 200 “Own funds and Eligible Liabilities” in M01.00, filling row 200 with 950 (1.000 – 50) in the example above.  On the other hand, with reference to rows 250 and row 280 to row 290, the Bank would like to have further guidance on which of the following filling approaches is correct: Option A : not adding unused GPP to Other bailinable liabilities. In the example above the Bank should fill row 250 with 3.000. Following this criterion, also the sum of rows 280 to 290 would be 3000. Option B :  adding unused GPP to Other bailinable liabilities. In the example above the Bank would fill: row 250 with 3.050 (3.000 + 50) row 280 with 1.550 (1.500 + 50) -> since at the reporting time it is not known for which specific instrument the unused general prior permission might be used, the Bank allocated all the amount on r0280 by default with the purpose of consistency between r0250 and the sum of rows 280+285+290. Row 285 with 700. Row 290 with 800. Option C:   adding unused GPP to Other bailinable liabilities only in row 250 (with this option the amount in 250 would not reconciliate with the sum of 258+285+290, breaching EBA Validation Rule v10743_m.