Extended quarter-end reporting
When does the extended quarter-end reporting apply?
The use of the reference period in Article 5(1) of the AnaCredit Regulation implies that instruments are reported until at least the end of the quarter in which the debtor’s commitment amount falls below the reporting threshold of €25,000. Furthermore, Part I (Section 5.2.1) and Part II (Section 3.1.6) of the Manual clarify that this quarter-end extended reporting is of particular relevance for written-off instruments, and aims at capturing the total write-off amount via the accounting dataset as of the quarter-end reporting reference date. On the other hand, however, Section 5.2.3 (including Example 21) in Part I of the Manual stipulates that instruments for which no write-off has occurred also have to be reported in the extended period.
In connection with the above, the following additional clarification is requested.
If, during the quarter, the debtor’s commitment amount (being the sum of the outstanding nominal amount and off-balance-sheet amount of all instruments of the debtor) falls below the threshold, should the instrument(s) continue to be reported until the end of the quarter, or are they expected to disappear from the reporting the next month?
It is clarified that the reporting till quarter-end concerns eligible instruments which incur a write-off. Otherwise, in cases where there is no write-off, if the debtor's commitment amount falls below the reporting threshold of €25,000, the instruments are not subject to reporting after the drop in the debtor's commitment amount.
Furthermore, it is clarified that the explanation provided in Section 5.2.1 in Part I of the Manual concerning the applicability of the extended quarter-end reporting takes precedence over the general rules provided in Section 5.2.3. In this context, Example 21 presented therein should read that an amount was written off in the period between 1 January 2019 and 31 March 2019, rather than repaid by the debtor as erroneously stated in the example.
For an illustration, please see the following examples.
An instrument which is reported to AnaCredit for reporting reference dates 31 December through to 28 February is fully repaid on 14 March. The instrument does not incur any loss in the period concerned. Consequently, the instrument is not reported to AnaCredit as of 31 March and the last record available in AnaCredit relates to 28 February. Furthermore, the last quarterly information available for the instrument goes back to 31 December.
A debtor has only one instrument. On 31 January the debtor’s commitment amount is €27,000 vis-à-vis the observed agent and the instrument is reported to AnaCredit at the reporting reference date. On 17 February, the debtor makes a payment (e.g. of €5,000), which results in the debtor's commitment amount falling below the reporting threshold. The debtor’s commitment amount does not increase thereafter. In this case, the instrument is not reported as of 28 February or as of 31 March.
A debtor has only one instrument. As of 31 January the debtor’s commitment amount is €40,000 vis-à-vis the observed agent and the instrument is reported to AnaCredit. As of 14 February a part of the instrument is subject to securitisation, where €20,000 is transferred in a true sale to an SPV. The observed agent keeps the servicing rights of the transferred part of the instrument.
In this case, the partial transfer does not reduce the outstanding nominal amount (see Section 4.4.3 in Part II of the Manual) and the debtor’s commitment amount is still €40,000, even after the transfer. Consequently, the reporting of the instrument continues after the transfer date.
A debtor has only one instrument. As of 31 March the debtor’s commitment amount is €80,000 vis-à-vis the observed agent and the instrument is reported to AnaCredit. On 9 April the instrument is sold to a third party. The observed agent does not keep the servicing rights of the sold instrument.
In this case, the observed agent neither holds nor services the instrument after the sale. Furthermore, as the observed agent does not incur a loss that needs to be captured in AnaCredit (i.e. no write-off), the observed agent does not report the instrument after the sale (see Section 3.1.6 in Part II of the Manual).