QA2022-57 - Question on reporting of intragroup liabilities

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Feb 01, 2024
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Resolution Reporting Subject Matter Guidance
Guidance Documents Intragroup-liabilities
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QA2022-57

Question


LDR T1 line 0210 (Liabilities towards other entities of the resolution group (BRRD art. 44/2/h)) was introduced in the 2022 version of the LDR. Counterparty columns 004x (institutions), 005x (other financial corporations) and 006x (OFC of which insurance firms and pension funds) are open for input. Other counterparty columns like 003x (corporates) are greyed out/not open for input. How does a credit institution report intragroup liabilities received from subsidiaries within its prudential consolidation scope, that are classified as Corporates? As column 003x is not open for input, it is currently not possible to classify these liabilities as ‘Corporates’ in the LDR. Can column 003x, for line 0210 of LDR form T1 be opened for input?


Response


Row r0210 of template T01.00 covers exclusively the scope of Art. 44(2)(h) BRRD regarding liabilities excluded from the application of write down and conversion powers. Specifically, this article covers institutions or entities referred to in point (b), (c) or (d) of Art. 1(1) BRRD. As such, “corporates” are not in the scope of Art. 44(2)(h) BRRD and should be reported in row r0210. For the case at hand, intragroup liabilities received from subsidiaries classified as “corporates” and included in the prudential scope of consolidation of the reporting entity should be reported among the liabilities in scope of the bail-in tool according to the type and maturity of the liability, unless otherwise within the scope of Art. 44(2) BRRD. It remains understood that letter (h) of Art. 44(2) BRRD is not applicable for counterparties classified as “corporates”.