QA2022-27 - FMIR scope

Owned by SRB Services
Feb 01, 2024
Atribute Detail
Resolution Reporting Subject Matter Guidance
Guidance Documents FMIs
Taxonomy -
Unique Identifier

QA2022-27

Question


The guidance on the FMIR specifies that the scope covers the Relevant Legal Entity of a resolution group, whereas the T31.00 asks for the mapping of the FMI with the critical function supported by the FMI. What happens when a subsidiary, qualified as RLE, does not exercise any critical function? Should we report the data linked to the use of the FMI by this subsidiary in the T30.00 and nothing in the T31.00 so that the ID of this specific user and FMI won't appear in the T31.00 ? Or is the scope of the FMIR the combination of RLE/critical function only ?


Response


T30.00 should be completed based on the scope defined per paragraph 1.1 of the FMIR guidance, i.e. “[…], the FMI report shall cover all the FMI accesses and use of intermediaries for payment, clearing, custody, and settlement services of all legal entities requested by the resolution authority. Reporting is mandated for Relevant Legal Entities (RLEs), as well as other entities, identified by IRTs as falling within the scope of this exercise. Please refer to the Guidance on the Liability Data Report for the definition of RLEs.” Of the FMI service providers identified in T30.00, T31.00 should include those ones that provide services that are necessary to the reporting institution for the provision of at least one critical function. The IRT will assume that the bank considers the FMI service providers mapped to critical functions in T31.00 as critical. A separate line needs to be generated for each critical function associated to a given ID reported in column 0010 of T31.00. Therefore, it is possible that an FMI service provider that is identified in T30.00 does not show up in T31.00.