Question
What is the correct reporting of an exposure to company A if this exposure is guaranteed by the explicit guarantee by central government (this central government with 0% RW) - such exposure is subject to an exemption under Article 400(1)(c)?
Background on the question
Following the instructions (LE2 template/LE3 template), all exempted exposures should be reported in column 320 of LE2/330 of LE3 (amounts exempted). Can you please confirm that such exposures (exposures guaranteed by central governments, where unsecured claims on the entity to which the exposure is attributable or by which it is guaranteed would be assigned a 0%RW) which are exempted under Article 400 – should be reported in column 320 of LE2 / column 330 of LE3 - exempted exposures? For example, a 100 € debt instrument exposure with company ‘A’, guaranteed by a central government (exemption under Article 400), should be reported: company ‘A’ row: Column 090 = 100; Column 330 (exemptions) = -100; or substitution effect should be shown in the templates although instructions require that all exempted exposures are reported in mentioned two columns. For company ‘A’ row (LE2): Columns ‘direct exposures’ = 100; Columns ‘substitution effect’ = -100; For ‘Government’ row: column ‘indirect exposures’ = 100; column 330 ‘exemptions’ = -100
Answer
On the basis of the question raised by the submitter, the correct reporting behaviour shall be the following according to chapter 6.1 (Instructions concerning specific columns) of Annex IX to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting): Template LE2 (C 28.00) of Annex VIII to the ITS on Supervisory Reporting: Row / code for A (the company) column 060 (‘Original exposures – Direct exposures – Debt instruments’): 100 column 210 (‘Exposure value before application of exemptions and CRM’): 100 column 240 (‘(-) Substitution effect of eligible credit risk mitigation techniques’): – 100 column 330 (‘Total’): 0 Row / code for the Central Government column 120 (‘Original exposures – Indirect exposures – Debt instruments): 100 column 210 (‘Exposure value before application of exemptions and CRM’): 100 column 320 (‘(-) Amounts exempted’) - 100 column 330 (‘Total’) = 0; The same reporting approach shall be followed for providing the information requested in the template LE3 (C 29.00) of Annex VIII to the ITS on Supervisory Reporting.