Atribute	Detail
Resolution Reporting Subject Matter	Guidance
Guidance Documents	Intragroup-liabilities
Taxonomy	-
Unique Identifier	QA2022-43

Question

We need some clarifications regarding derivative intragroup liabilities meeting the conditions under article 44/2/h of the BRRD2. Our understanding is that they should be reported in the new row r0210 and therefore be excluded from row 330 (for the carrying amount) and 334 (for the outstanding amount), following the top to bottom approach. 1. If our interpretation is correct, the intragroup carrying amount of the derivatives meeting the conditions under article 44/2/h of the BRRD2 shall be reported in row 0210 instead of row 330. As a consequence, the ldt_corep_finrep rule SRBDQ_0346 (T01.00-r0330-c0121 = FINREP F01.02-020-010 + F01.02-150-010 + F01.02-062-10) cannot not be respected. Considering that the severity of such rule is “warning”, are we expected to justify the inconsistency accordingly (ie. as a result of the abovementioned switch)? 2. The intragroup outstanding amount of the derivatives meeting the conditions under article 44/2/h of the BRRD2 shall be reported in row 210 instead of row 334. Following what indicated in the guidance (derivatives are specific in nature and should not be reported under T03.01), these intragroup derivatives shall not be included in the template T03.01, even if they are now reported at row 210. Could you please confirm whether this approach is in line with your expectations? 3. Finally, considering that rows 331, 332 and 333 do not contribute to the total liabilities outstanding amount of T01.00 and thus, they cannot be reported under the new row 210, should they be fed net or gross of intragroup liabilities meeting the conditions under article 44/2/h of the BRRD2?

Response

An intragroup derivative instrument meeting the conditions set out in Article 44(2)(h) BRRD shall be considered excluded from the scope of the bail-in tool and, as such, it should be reported in row r210 of template T 01.00. Accordingly, its carrying and outstanding amounts should not be reported in rows r330 and r334, respectively. Moreover: 1) Under the scenario described in the question, validation rule SRBDQ_0346 should not be applicable. The severity rule of “Warning” clarifies that there may be specific circumstances under which this rule may provide false positive results. This is one of those instances. We encourage the reporting entities to clarify with the IRTs the reasons why this rule is triggered; 2) Derivative instruments shall not be reported in template T 03.01, whether they meet the conditions set out in Article 44(2)(h) BRRD or not; 3) All other derivative instruments falling outside the scope of row r210 of template T 01.00 should be reported in rows r331-r333 of the same template. Accordingly, the amounts reported in rows r331-r333 should be net of the intragroup derivative instruments meeting the conditions of Article 44(2)(h) BRRD.

Related articles

Page:
QA2025-21- LDR - Reporting of Trading Portfolio Liabilities (Questions and Answers)
Page:
QA2025-13- CFR Guidance and the use of ECB statistics for the denominator in the market share calculations (Questions and Answers)
Page:
QA2025-12- Due date for reporting of MREL TLAC Q1 2025 (Questions and Answers)
Page:
QA2024-42 - SRB Taxonomy Package 9.03 (Questions and Answers)
- qa
- guidance
- fmis
- kb
Page:
QA2024-41 - 2025 SRB Txonomy (Questions and Answers)
Page:
QA2024-21 - Statistical data availability (Questions and Answers)
Page:
QA2024-17 - Clarification regarding the value of transactions on proprietary accounts for OTC swaps (Questions and Answers)
- qa
- guidance
- fmis
- kb
Page:
QA2024-23 - FMIR T33.00 c0090 Value of transactions on proprietary accounts (Questions and Answers)
- qa
- guidance
- fmis
- kb
Page:
QA2024-16 - ECB Market Data for Payments to MFIs and Non-MFIs (Questions and Answers)
Page:
QA2024-12 - Filing indicator for 2024 resolution reporting cycle (Questions and Answers)
Page:
QA2024-14 - T12 (Questions and Answers)
Page:
QA2021-8 - Reporting UK law issuances in the LDR at 31-12-2020 (Questions and Answers)
Page:
QA2021-4 - T07.00 & T08.00 Type of MA (Questions and Answers)
Page:
QA2021-17 - Are the central bank exposures excluded from the calculation of the TEM? (Questions and Answers)
Page:
QA2021-64 - Treatment of SMEs under households in reporting (Questions and Answers)
- kb
- qa
- guidance
- -

Browser not supported