The rule in plain words
For past due > 90 days: loans and advances collateralised by immovable property cannot be less than loans and advances to small and medium-sized enterprises (NFCs) collateralised by commercial immovable property plus loans and advances to non-financial corporations (NFCs) other than SMEs collateralised by commercial immovable property.
EBA checks it for ten columns, from gross carrying amount (0010) to exposures with forbearance measures (0110). That makes ten checks. A failure names the one that failed.
How the Line4 Check report words itShowHide
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.
of which: Exposures with forbearance measures: Loans and advances collateralised by immovable property >= Loans and advances to small and medium-sized enterprises (NFCs) collateralised by commercial immovable property + Loans and advances to non-financial corporations (NFCs) other than SMEs collateralised by commercial immovable property
What to do if your filing fails it
- 01Open the template below and find the cells the rule reads.
- 02Compare the values in your file. If the first is smaller than it may be, one of them is wrong: check both before you change either.
- 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
- 04It runs only when your filing indicators mark F 23.03 as reported.
- 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
Loans and advances collateralised by immovable property: Breakdown by LTV ratios (F 23.03)
Rows
- 0010Loans and advances collateralised by immovable property
- 0050Loans and advances to small and medium-sized enterprises (NFCs) collateralised by commercial immovable property
- 0090Loans and advances to non-financial corporations (NFCs) other than SMEs collateralised by commercial immovable property
Columns
- 0010Gross carrying amount
- 0020of which: Exposures with forbearance measures
- 0030Performing
- 0050of which: Exposures with forbearance measures
- 0060Non Performing
- 0070of which: Exposures with forbearance measures
- 0080Unlikely to pay that are not past due or past due <= 90 days
- 0090of which: Exposures with forbearance measures
- 0100Past due > 90 days
- 0110of which: Exposures with forbearance measures
A worked example
The first of its checks, with simple numbers.
Loans and advances collateralised by immovable property must then be at least 2,000.
A file that reports 2,000 passes. One that reports 1,900 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, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.
{F_23.03,r0010,c0110,} >= {F_23.03,r0050,c0110,} + {F_23.03,r0090,c0110,}The next five:
{F_23.03,r0010,c0010,} >= {F_23.03,r0050,c0010,} + {F_23.03,r0090,c0010,}{F_23.03,r0010,c0050,} >= {F_23.03,r0050,c0050,} + {F_23.03,r0090,c0050,}{F_23.03,r0010,c0060,} >= {F_23.03,r0050,c0060,} + {F_23.03,r0090,c0060,}{F_23.03,r0010,c0100,} >= {F_23.03,r0050,c0100,} + {F_23.03,r0090,c0100,}{F_23.03,r0010,c0020,} >= {F_23.03,r0050,c0020,} + {F_23.03,r0090,c0020,}And 4 more, the same formula for the other cells it covers.
Other rules on F 23.03
- Loans and advances collateralised by immovable property cannot be less than the sum of three rows (v7978_m)Warning
- Non Performing: loans and advances collateralised by immovable property cannot be less than the sum of two rows (v7980_m)Warning
- Past due > 90 days cannot be less than exposures with forbearance measures (v7977_m)Warning
- Loans and advances to small and medium-sized enterprises (NFCs) collateralised by commercial immovable property cannot be less than the sum of three rows (v7981_m)Warning
- Past due > 90 days must equal the sum of its six parts (v7976_m)Warning
- Loans and advances to non-financial corporations (NFCs) other than SMEs collateralised by commercial immovable property cannot be less than the sum of three rows (v7982_m)Warning
- Unlikely to pay that are not past due or past due <= 90 days cannot be less than exposures with forbearance measures (v7975_m)Warning
- Commercial Real Estate loans to small and medium-sized enterprises (NFCs) collateralised by immovable property cannot be less than the sum of three rows (v7983_m)Warning
Every FINREP 9 rule, by template
Checks like this one, run at the point of submission, are the first step to real-time supervision.
