Reportable data attributes during the extended quarter-end reporting
Instruments that incur a loss are reported until at least the quarter-end date on which the write-off took place. However, clarification is needed about how to report written-off instruments in the extended period of reporting (i.e. until the quarter-end) and beyond? In particular, how to report instruments which incur a loss and are transferred to a third party? Often such instruments are not kept in the IT systems after the transfer and it would be costly for reporting agents to maintain this information in the systems until the quarter-end.
Instruments are in principle subject to AnaCredit reporting only if they are held or serviced by the observed agent. However, there is an exception regarding instruments that incur a write-off as such instruments are reported until at least the end of the quarter in which the write-off occurs.
With regard to instruments with a write-off, Section 184.108.40.206 in Part II of the Manual provides that, broadly speaking, two possibilities emerge, generally depending on whether or not the instrument is still held or serviced by the observed agent.
Particularly regarding written-off instruments that are no longer held or serviced by the observed agents, the ECB acknowledges the fact that such instruments are typically not in observed agents’ systems. And although such instruments are required to be reported until exactly the quarter-end, it is clarified that the only relevant datasets that have to be reported in such cases are the financial dataset and the accounting dataset (following their respective reporting frequency), while the remaining datasets are in principle not reportable. Please note that in regard to the financial and accounting dataset, only very few data attributes are actually applicable during this extended reporting period; these include, in particular, the “outstanding nominal amount” (which is reported as 0), the “accumulated write-offs” and the “cumulative recoveries since default”, while the vast majority of data attributes no longer apply.
A debtor has one instrument vis-à-vis an observed agent and the instrument is reported to AnaCredit as of 30 April. In May, the instrument is fully written off. Should the financial dataset be reported for the written-off instrument after the write-off moment on a monthly basis?
Yes, the financial dataset of the instrument is reported on a monthly basis only until the quarter-end.
A debtor has two instruments vis-à-vis an observed agent and the instruments are reported to AnaCredit as of 30 April. In May, one instrument is fully written off. Should the financial dataset be reported for the written-off instrument after the write-off moment on a monthly basis?
Yes, the financial dataset of the instrument is reported on a monthly basis until the quarter-end, and beyond that if the instrument is still held or serviced by the observed agent and the commitment amount of the other instrument exceeds the reporting threshold.
Please refer to Section 220.127.116.11 in Part III of the Manual for a comprehensive example of AnaCredit reporting related to a written-off loan that is no longer held or serviced by the observed agent.
See also Extended quarter-end reporting