Line4

2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Loans collateralised by commercial immovable property cannot be more than the sum of three rows (EBA rule v7883_m)

A warning in the financial reporting return (FINREP 9), on template F 18.02.a, commercial Real Estate (CRE) loans and additional information on loans secured by immovable property (I).

Check your file against this ruleWhat to do if it fails

The rule in plain words

Loans collateralised by commercial immovable property cannot be more than these three added up:

  • Loans with LTV ratio higher than 60% and less than or equal to 80%
  • Loans with LTV ratio higher than 80% and less than or equal to 100%
  • Loans with LTV ratio higher than 100%

EBA checks it for 13 columns, from accumulated impairment, accumulated negative changes in fair value due to credit risk (0180) to non-performing exposures with forbearance measures (0300). That makes 13 checks. A failure names the one that failed.

How the Line4 Check report words itShow

The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.

Accumulated impairment, accumulated negative changes in fair value due to credit risk: Loans collateralised by commercial immovable property <= Of which: Loans with LTV ratio higher than 60% and less than or equal to 80% + Of which: Loans with LTV ratio higher than 80% and less than or equal to 100% + Of which: Loans with LTV ratio higher than 100%

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is bigger than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark F 18.02 as reported.
  5. 05This 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

Commercial Real Estate (CRE) loans and additional information on loans secured by immovable property (I) (F 18.02.a)

Rows

  • 0030Loans collateralised by commercial immovable property
  • 0040Of which: Loans with LTV ratio higher than 60% and less than or equal to 80%
  • 0050Of which: Loans with LTV ratio higher than 80% and less than or equal to 100%
  • 0060Of which: Loans with LTV ratio higher than 100%

Columns

  • 0180Accumulated impairment, accumulated negative changes in fair value due to credit risk
  • 0190of which: Exposures with forbearance measures
  • 0200Performing exposures - Accumulated impairment
  • 0210Of which: Performing exposures with forbearance measures
  • 0220Non-performing exposures - Accumulated impairment, accumulated negative changes in fair value due to credit risk
  • 0230Unlikely to pay that are not past due or past due <= 90 days
  • 0240Past due > 90 days <= 180 days
  • 0250Past due > 180 days <= 1 year
  • 0260Past due > 1 years <= 2 years
  • 0270Past due > 2 years <= 5 years
  • 0280Past due > 5 years <= 7 years
  • 0290Past due > 7 years
  • 0300Of which: Non-performing exposures with forbearance measures

A worked example

The first of its checks, with simple numbers.

Illustrative values
Loans with LTV ratio higher than 60% and less than or equal to 80%1,200
Loans with LTV ratio higher than 80% and less than or equal to 100%800
Loans with LTV ratio higher than 100%450
Together2,450
What the rule then expects

Loans collateralised by commercial immovable property can then be at most 2,450.

2,450Passes
2,550Fails

A file that reports 2,450 passes. One that reports 2,550 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

Show the rule as writtenShow

EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.

{F_18.02.a,r0030,c0180,} <= {F_18.02.a,r0040,c0180,} + {F_18.02.a,r0050,c0180,} + {F_18.02.a,r0060,c0180,}

The next five:

{F_18.02.a,r0030,c0220,} <= {F_18.02.a,r0040,c0220,} + {F_18.02.a,r0050,c0220,} + {F_18.02.a,r0060,c0220,}{F_18.02.a,r0030,c0280,} <= {F_18.02.a,r0040,c0280,} + {F_18.02.a,r0050,c0280,} + {F_18.02.a,r0060,c0280,}{F_18.02.a,r0030,c0250,} <= {F_18.02.a,r0040,c0250,} + {F_18.02.a,r0050,c0250,} + {F_18.02.a,r0060,c0250,}{F_18.02.a,r0030,c0300,} <= {F_18.02.a,r0040,c0300,} + {F_18.02.a,r0050,c0300,} + {F_18.02.a,r0060,c0300,}{F_18.02.a,r0030,c0230,} <= {F_18.02.a,r0040,c0230,} + {F_18.02.a,r0050,c0230,} + {F_18.02.a,r0060,c0230,}

And 7 more, the same formula for the other cells it covers.

Every FINREP 9 rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.