The rule in plain words
Eligible liabilities subordinated to excluded liabilities must equal these five added up:
- Eligible liabilities instruments issued directly by the resolution entity (not grandfathered)
- Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered)
- Eligible liabilities instruments issued prior to 27 June 2019
- Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items
- (-) own eligible liabilities instruments subordinated to excluded liabilities
All the values are in the memo item: amounts eligible for the purposes of MREL, but not TLAC column (0030) of M 02.00.c.
How the Line4 Check report words itShowHide
Word for word as the report shows it when the rule fails.
Eligible liabilities subordinated to excluded liabilities = Eligible liabilities instruments issued directly by the resolution entity (not grandfathered) + Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered) + Eligible liabilities instruments issued prior to 27 June 2019 + Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items + (-) Own eligible liabilities instruments subordinated to excluded liabilities
What to do if your filing fails it
- 01Open the template below and find the cells the rule reads.
- 02Add up the parts in your file and compare the result with the total.
- 03If they differ, a part is missing, a value sits in the wrong row, or the total is out of date.
- 04EBA allows a small rounding difference, worked out from the decimals each value is reported with.
- 05It runs only when your filing indicators mark M 02.00 as reported.
- 06This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.
The cells it reads
MREL and TLAC capacity and composition (resolution groups / entities) (TLAC1) (III) (M 02.00.c)
Rows
- 0090Eligible liabilities subordinated to excluded liabilities
- 0100Eligible liabilities instruments issued directly by the resolution entity (not grandfathered)
- 0110Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered)
- 0120Eligible liabilities instruments issued prior to 27 June 2019
- 0130Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items
- 0132(-) Own eligible liabilities instruments subordinated to excluded liabilities
Column
- 0030Memo item: Amounts eligible for the purposes of MREL, but not TLAC
A worked example
The first of its checks, with simple numbers.
Eligible liabilities subordinated to excluded liabilities must then be 2,900.
A file that reports 2,900 passes. One that reports 3,000 fails, by 100.
The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.
Show the rule as writtenShowHide
EBA's formula. Cells are written as {template, row, column, sheet}.
{M_02.00.c,r0090,c0030,} = {M_02.00.c,r0100,c0030,} + {M_02.00.c,r0110,c0030,} + {M_02.00.c,r0120,c0030,} + {M_02.00.c,r0130,c0030,} + {M_02.00.c,r0132,c0030,}Other rules on M 02.00.c
- Eligible liabilities not subordinated to excluded liabilities must equal the sum of its three parts (v22342_m)Warning
- Memo item: amounts eligible for the purposes of MREL, but not TLAC cannot be more than zero (v22350_s)Warning
- Eligible liabilities items before adjustments must equal the sum of its two parts (v10850_h)Warning
- Memo item: amounts eligible for the purposes of MREL, but not TLAC cannot be negative (v10838_s)Warning
- Own funds must equal the sum of its three parts (v903590_m)Warning
Every MREL and TLAC rule, by template
Checks like this one, run at the point of submission, are the first step to real-time supervision.
