Reporting of losses from lending collateralised by immovable property (C_15.00)

For loans secured by real estate property with any of the credit history scenarios below, should losses, and in case of scenario iii., exposures, be reported in COREP template C 15.00?  If yes, for which default event or events should the estimated losses be included in the reporting (i.e. is it correct to assume that under scenario ii. only losses estimated for the last default event in the reporting period should be included)?  Also, which default event should be used as a reference date for the reported exposures under scenario i. (the reporting period or the year prior to it) and under scenario ii. (exposure value at the first or at the last default event during the reporting period)? i. scenario:  The loan secured by real estate property had defaulted in a year prior to the reporting period, subsequently it exited/cured from the default state in the reporting period, but later it defaulted again during the same reporting period, and it stayed in the default state until the end of the period. ii. scenario:  The loan secured by real estate property had defaulted in the reporting period, later it exited/cured from the default state in the same reporting period, but still in the same period it defaulted again and stayed in the default state until the end of the period. iii. scenario: The loan secured by real estate property had defaulted in the reporting period and subsequently in the same period the institution stopped recognising the real estate property as CRR-eligible collateral (the real estate property ceased to meet the eligibility criteria).

We have observed potentially diverging practices amongst reporting agents with regard the inclusion of defaulted loans secured by real estate property that have a credit history described in the question above.  According to both Regulation (EU) 2021/451 and Regulation (EU) 2024/3117 (repealing the former) Annex VII 4. on Reporting of exposures and losses, the reference date for estimated losses on defaulted loans secured by real estate property shall include all defaults that occur during the reporting period, while for related exposures the reference date is the date just before the default. It is also stated that losses shall be reported only for exposures having defaulted during the reporting period, therefore changes to losses of exposures having defaulted during previous reporting periods will not be reflected in the reported data, however, this refers specifically to proceeds from the realisation of the collateral at a later reporting period or lower realised costs than previously estimated shall not be reported. The definition of losses complements this stating the losses shall be reported as soon as provisions are to be booked in accordance with accounting rules.