Question
Should all assets deducted from own funds be reported under Original Exposure pre conversion factors (C07.00 - column 0010) and hence considered as Value adjustments and provisions associated with the original original exposure (C07.00 - column 0030)
Background on the question
According to CRR Article 111.1, "The exposure value of an asset item shall be its accounting value remaining after specific credit risk adjustments in accordance with Article 110, additional value adjustments in accordance with Article 34 related to the non-trading book business of the institution, amounts deducted in accordance with Article 36(1), point (m), and other own funds reductions related to the asset item have been applied. According to the Final Draft ITS on supervisory reporting (DPM4.0_EBA ITS 2024_06) or (EU 2021_451): Annex II 3.2.5 Column 0010 (Original Exposure pre-conversion factors) is defined as being "Exposure value calculated in accordance with Article 111 CRR without taking into account value adjustments and provisions, deductions, conversion factors and the effect of credit risk mitigation techniques with the following qualifications stemming from Article 111(2) CRR XXX"; Annex II 3.2.5 Column 0030 (-) Value adjustments and provisions associated with the original exposure is defined as being "Article 24 and 111 CRR Value adjustments and provisions for credit losses (credit risk adjustments in accordance with Article 110) made in accordance with the accounting framework to which the reporting entity is subject, as well as prudential value adjustments (additional value adjustments in accordance with Article 34 and 105, amounts deducted in accordance with point (m) Article 36(1) and other own funds reductions related to the asset item)." It is unclear from the above if all assets deducted under CRR article 36 (e.g intangible, deferred tax, defined benefit pension fund assets, direct holding of FS entities) should also be considered under Column 0010 Original Exposure pre-conversion factors, CRR Article 111.1 specifically referring to Article 36(1) m and to own funds reductions rather than "other own funds deductions foreseen in article 36) Moreover, unlike foreseen for Large Exposure reporting framework (Template 28, Column 200 - Exposures deducted from Common Equity Tier1), there is no column foreseen in template C07.00 to do so. Deductions under article 36 are not Value Adjustments or Provisions associated with the original exposure (content of the column still refers to own funds reductions but with no further specifications whereas other instructions are ref. to specific CRR articles).
Answer
This question has been rejected because the issue it deals with is already explained or addressed in Regulation (EU) No 575/2013 and by Implementing Regulation (EU) 2021/451 (ITS on Reporting). For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'.