Question
In template B, should banks publish gross or net positions in the case of derivative transactions, where collateral could be posted and received between the two same counterparties?
Background on the question
Should banks publish gross or net positions for their derivative transactions?
Answer
Publication of collateral amounts arising from derivative positions should follow the same provisions applicable for the supervisory reporting of Asset Encumbrance under Commission Implementing Regulation (EU) 2015/79. Q&A 2013_468 has explained how derivative transactions have to be reported for financial reporting purposes in FINREP and how netting rules should be considered, and in particular that the principles in paragraphs 42 to 50 and AG38-AG39 of IAS 32, or national rules for netting for non-IFRS institutions, shall apply regarding the potential for netting different derivative transactions. Nevertheless, netting rules as per IAS 32 or national rules are applicable only in the case of on-balance sheet financial instruments. According to the guidelines on disclosure of encumbered and unencumbered assets (Title II paragraph 3), institutions should disclose encumbered and unencumbered collateral "received that does not meet the conditions to be recognised on the balance sheet of the transferee in accordance with the applicable accounting framework" in Template B. Therefore, the netting rules in IAS 32 or national accounting frameworks do not apply to the disclosure of collateral in Template B. To give to users an appropriate view of encumbered and unencumbered collateral received, collateral should be reported in Template B on a gross basis, without netting collateral posted and received for a single counterparty.