Reporting Instructions

Reporting Instructions Template 1: Portfolio Segmentation The template is filled in with values (amounts in thousands euro and numbers in units where ...
Author: Priscilla Poole
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Reporting Instructions Template 1: Portfolio Segmentation The template is filled in with values (amounts in thousands euro and numbers in units where appropriate) for selected items (in rows) per category of exposure allocated in the respective columns and repeated for every asset portfolio in the respective groups of rows. The “reference date” shall be the 31/3, 30/06, 30/09 and 31/12, while the “reference period” shall be the first, second, third and fourth quarter respectively.

1. Category of Exposures “Exposure” means an asset or off-balance sheet item (Regulation EU No 575/2013, Article 5). Exposures, for the purposes of this Act, are split into the following categories: A. Gross Loans (B+C), (ΕΒΑ, Annex V. Part 2. 145-162). No data shall be reported to this column, as this shall be automatically filled in with the data reported in columns B “Total Performing Exposures” and C “Total Non-Performing Exposures”. 

of which with Forbearance Measures. No data shall be reported to this column, as this shall be automatically filled in with the total of the data reported in the columns that refer to Performing and Non-Performing Exposures with Forbearance Measures.

B. TOTAL Performing Exposures. No data which refers to Performing Exposures (ΕΒΑ, Annex V. Part 2. 145162) shall be reported to this column (except the items “Collateral” and “Write-offs”) as this shall be automatically filled in with the total of data reported according to the following buckets (ΕΒΑ, Annex V. Part 2. 158):     

Current. Subcategory of exposures with 0 days past due. 1-30 dpd. Subcategory of exposures with 1-30 days past due. 31-60 dpd. Subcategory of exposures with 31-60 days past due. 61-90 dpd. Subcategory of exposures with 61-90 days past due.

of which with Forbearance Measures. This column shall be filled in with the amounts referring to the Performing Exposures with Forbearance Measures (EBA, Annex V. Part 2. 145-162).

C. TOTAL Non-Performing Exposures (D+E+F), (ΕΒΑ, Annex V. Part 2. 145-162). No data shall be reported to this column as this shall be automatically filled in with the total of columns which are split into the following categories of exposures (D, E and F). 

of which with Forbearance Measures. No data shall be reported to this column which refers to Performing Exposures with Forbearance Measures (ΕΒΑ, Annex V. Part 2. 145-162) as this shall be automatically filled in with the total of columns with the exposures with forbearance measures of categories D and E analyzed below.

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D. Unlikely to Pay that are not past due or past due ≤90 dpd. Subcategory of exposures deemed as NonPerforming even though they are either under “current” status either under “past due up to 90 days” status. (ΕΒΑ, Annex V. Part 2. 159). 

of which with Forbearance Measures. This column shall present the exposures with forbearance measures of D category.

E. Exposures in Arrears, above 90 dpd excluding Denounced Loans. The column presents the subcategory of exposures that are in arrears status, above 90 dpd. For the purposes of this template, denounced loans as defined below are excluded. The column shall be filled in with the amounts for “Collateral” and “Writeoffs”. No data shall be reported to this column for the rest categories as this shall be automatically filled in with the total of subcategories (buckets) below:     

91-180 days [91-180 dpd]. Category’s E exposures in arrears from 91-180 days. 181-360 days [181-360 dpd]. Category’s E exposures in arrears from 181-360 days. 361-1080 days [361-1080 dpd]. Category’s E exposures in arrears from 361-1080 days. 1081+ days [1081+ dpd]. Category’s E exposures in arrears above 1081 days (3 years).

of which with Forbearance Measures. The column shall present exposures with forbearance measures of E category

F. Denounced Loans. Denounced loans are loans which their contract has been called on by the lender and the denouncement has been properly announced to the debtor. No data shall be reported to this column (except “Collaterals”) as this shall be automatically filled in with the total of the three (3) subcategories of F category analyzed below. For those loans where an application to bankruptcy process has been filled but the definitive court’s decision is pending shall be considered as loans “Not under Bankruptcy Procedures”. 





Not Under Bankruptcy Procedures - Without Settlement. The column presents denounced loans that were not subject to bankruptcy procedures and no settlement has been reached. The column shall not be filled in with the amounts for “Collateral”. Not Under Bankruptcy Procedures - Under Settlement. The column presents denounced loans that were not subject to bankruptcy procedures, but settlement has been agreed with the debtor, under which the debtor conducts regular pre-agreed payments to the lender. In case that the debtor fails to comply with the terms of the settlement for more than three months, the denounced loan shall be reported to category “Not under Bankruptcy Procedures - Without Settlement”. The column shall not be filled in with the amounts for “Collateral”. Under Bankruptcy Procedures. The column shall present denounced loans for both physical and legal persons that are subject to bankruptcy process. The column shall not be filled in with the amounts for “Collateral”.

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2. Key data for Template 1 For the purposes of Template 1 with clear distinction to the respective columns per exposure category (as analyzed above) the following data shall be filled in:     







Loan Count. The number of loans shall be reported. All reporting figures of the templates shall be reported per loan and not per debtor. Balance. The balance of the exposure at the reporting date shall be reported. Off-Balance Sheet Exposure. The balance of the exposure which refers to off-balance sheet items at the reporting date shall be filled-in [EBA, Annex V. Part 2. 149, 155]. Arrears. The part of the exposure’s amount that has been in arrears (i.e. the amount that has not been paid within the contractual period) shall be reported. Collateral. The value of the collaterals that is associated to the respective exposures. Collaterals shall not include personal or corporate guarantees. For the exposures reported under category B and E, the allocation of collaterals per bucket will not be filled-in. For the exposures reported under category F (Denounced Loans) only the total amount of the exposure shall be filled in, in the respective column, as no reporting is required per individual column. Where the value of the collateral(s) exceeds the outstanding amount of the exposure only the part of the value of the collateral(s) up to the outstanding amount of the exposure shall be reported. Accumulated Impairment. The amount of accumulated provisions (i.e. loan loss reserves / stock) that has been recognized for the respective exposures up to the reporting date shall be reported. Accumulated Impairment should be reported with a negative sign. Quarterly Impairment Losses. The amount of provisions (i.e. loan loss provisions / flow) for the respective exposures that has been recognized for the reporting period shall be reported. Provisions should be reported with a negative sign. Write-offs. The amount of write-offs that were charged for the reporting period shall be reported considering also the amount of the accumulated provisions that had been recognized for the respective exposures.

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3. Loan Categories Data of template 1, reported per exposure category in the respective columns, is further analyzed per asset class, according to Annex III of this Act, into repetitive groups of rows. More specifically, the total of loan portfolios’ is split into three main categories (Residential, Consumer and Business Loans) and it is further split into subcategories where appropriate. For the purposes of this Act, those subcategories are mutually exclusive. In that way the information reported for the three main categories arises from the respective aggregation of their subcategories. TOTAL. No data shall be reported at this section of the template, as this shall be automatically filled in with the total of the respective items (per line and column) of the three main categories of loan portfolios’. As a memo item, entities required to submit this report shall specify, for the total of their credit exposures, which of those exposures are to be included in the following categories, as those are defined in Annex III, and they shall report their items in the respective groups of lines: 



of which Public. Credit Exposures to: i) State Corporations and entities of private and public law, as those are defined by Greek Law 3429/2005, article 1, paragraph 1, 2, 3 and 6. ii) Regional and Local authorities. of which State-Related. Credit Exposures where: i) Greek State or Hellenic Fund for Entrepreneurship and Development (ETEAN S.A.) serves as guarantor or ii) a receivable from the Greek state exists (for example VAT receivable, accrued rent on buildings, unpaid government subsidy, invoices, receivables from infrastructure concessions). The two aforementioned subcategories are mutually exclusive. The exposures presented in those subcategories shall be included in the following categories of the loan portfolios below.

It should be clarified that this memo item refers only to Public entities under Greek Law and receivables from the Greek State. TOTAL Residential Loans. In this section exposures to households for the acquisition or the maintenance / refurbishment of residential property shall be reported. TOTAL Consumer Loans. No data shall be reported to this section as this shall be automatically filled in with the total of the respective items (per line and column) of the mutually exclusive loan portfolios mentioned below:  

Revolving Consumer Credit. Credit exposures to households for the coverage of consumer needs with a credit limit. Credit cards, overdrafts and revolving consumer loans shall be included. Non-revolving Consumer Credit. Credit exposures to households for the coverage of consumer needs with a predetermined amortization repayment schedule.

TOTAL Business Loans. No data shall be reported to this section as this shall be automatically filled in with the respective items (per line and column) of the six mutually exclusive loan portfolios mentioned below: 

Small Business & Professionals- SBPs. Credit exposures to professionals and businesses with turnover less than 2.5 million euro. 4



  



Small & Medium Enterprises - SMEs. Credit exposures to businesses with turnover above 2.5 million euro and below 50 million euro. Banks can override the turnover threshold based on internal organization of their business lines. Corporate. Credit exposures to businesses with turnover above 50 million euro. Shipping Finance. Credit exposures to shipping companies. Commercial Real Estate & Project Finance. Regarding commercial real estate, all exposures to companies that their source of income is generated from the development (sale or rent) of one or more commercial (office, commercial malls, warehouses etc.) or residential properties shall be included. Regarding project finance, the exposures that refer to the financing of the construction of infrastructure (for example motorways, airports, and power plants) shall be included. Typically, those loans will be serviced through the income that is generated from the operation of the asset. Financial Companies. Credit exposures to entities of the financial sector according to case 27, paragraph 1, article 4 of the EU regulation 575/2013 excluding credit institutions.

Corporate loans that are subject to the last three loan portfolios, shall not be included in the first three loan portfolios, regardless of companies’ turnover threshold. In that way those categories shall be mutually exclusive.

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