Question
In relation to SA General credit risk adjustments, as per template C 01.00, row 920, column 010, is an institution also required to report the respective values in column 050 in template C 09.01? Furthermore, should this credit risk adjustment apply for a bank and the bank is not including it in its Tier 2 capital, is the NCA obliged to inform the bank accordingly?
Background on the question
No instructions are given in Annex II - Reporting on own funds and own funds requirements in this regard. We currently have institutions which are reporting in row 920, column 010 of C 01.00 without reporting in C 09.01 and there are others who report in both templates. Some institutions are not reporting in C 01.00 but according to the RTS on the calculation of credit risk adjustments, such adjustment does apply.
Answer
General credit risk adjustments (GCRAs) shall be reported both in templates C 01.00, row 920, column 010 and C 09.01, column 050 of Annex I to Regulation (EU) 680/2014 (ITS on Supervisory Reporting). Column 050 of template C 09.01 shall reflect the amount of GCRAs before the application of the cap of Article 62(c) of Regulation (EU) No 575/2013 (CRR), i.e. the uncapped amount. It is the responsibility of the reporting entity to determine its Tier 2 capital, under control and review of the National competent authority. The reporting entity might choose not to recognize their GCRAs in Tier 2 as this constitutes a stricter prudential measure according to Article 3 CRR.