Clarifications regarding the reporting of off-balance-sheet amounts for financial leases
In Section 4.4.10 in Part II of the Manual it is stated that for financial leases (and some other types of instruments), “non-applicable” is in principle reported in the data attribute “off-balance-sheet amount” as these instruments do not link with an off-balance-sheet amount. Could you please confirm that, while, as a general rule, financial leases (and some other instruments) may not link with an off-balance-sheet amount, it may be the case that a value other than “non-applicable” should be reported?
Indeed. As a matter of fact, while the Manual clarifies that for financial leases, “non-applicable” is in principle reported in the data attribute “off-balance-sheet amount” as those instruments do not intrinsically link with an off-balance-sheet amount, it should be emphasised that this is what is typically expected in financial leases. That is, by stating that no off-balance-sheet amounts are, as a general rule, associated with financial leases, the Manual means to say that this is what usually happens, but not always.
Conversely, the statement that “non-applicable” is typically reported should not be interpreted as meaning that the off-balance-sheet amount (and the commitment amount at inception or any other data attribute) should not be reported for financial leases when there is one.
Consequently, while the data attribute may not apply in the case of most financial leases, it should be clarified that when the data attribute applies, it should be reported to AnaCredit, following the general clarifications regarding the data attribute.
For example, if financial leases, which can also be of a revolving nature, are part of a credit cross-limit, the data attribute “off-balance-sheet amount” for the financial leases should be reported following the general prescriptions applicable to off-balance-sheet amounts for cross-limits (see Q&A 2018/20). A similar reasoning applies to the data attribute “commitment amount at inception”.