Disclosures of Forborne and Non-Performing Exposures
This is an EBA requirement that is effective from 31 December 2019. The following text assumes that the disclosure needs will be applied regardless of Brexit.
- The disclosures are to be enhanced and there will be a general format applicable across financial institutions
- A set of additional templates will need to be populated by firms deemed to be significant i.e. those that have a gross NPL ratio (gross carrying amount of non-performing loans relative to the gross carrying amount of all loans excluding held for sale, cash balances at central banks and other demand deposits) of at least 5%.
Further details are in EBA guidelines 2018-10.
Amendment to the Branch Return
Firms that submit a branch return may want to be aware of policy statement 33-18 that introduces amendments. Changes are effective from 1 January 2019.
New Reporting for Mortgage Lenders and Administrators
The PRA and FCA issued consultation papers about the introduction of additional reporting requirements for mortgage lenders and administrators. The changes will affect Product Sales Data (PSD001 and PSD007) and MLAR.
The following information will be required:
- Internal transfer data regarding a move to a new loan product
- Contractual reversion rate offered
- Further advances – levels of outstanding debt, against which the property is secured, with the lender and any other firm
- Second charge – outstanding debt that is secured by a first charge
A new form MLA G1 will be introduced and be reported where a firm administers second charge mortgages but does not lend.
This form will be amended to include information regarding administration of a loan book on behalf of an unregulated entity.
Any changes described in the consultation papers are not expected to be effective until around the summer of 2020. Further information can be found in consultation papers PRA 30-18 and FCA 18-41.
Bank of England Reporting
Form AS – UK Monetary and Financial Institutions’ Holdings of Securities
Form FV – UK Resident Special Purpose Vehicles (income, expenditure and balance sheet)
The above two forms are to be introduced (both effective from 1 January 2019). Only firms that have been contacted directly by the Bank of England will need to submit them. Submissions will be to BEEDS.
Data for quarter one of 2019 will not need to be provided until after June of this year.
Form PL – Profit or Loss
Effective for January 2019 reporting:
- Holding companies’ interest payments on loans and interest receipts on deposits should be reported under ‘Captive Financial Institutions’ for the respective sector
- Any manufactured coupon payments on bonds and FRNs are to be reported in this line as a negative value
IFRS 9 Expected Loss Provision
The add back to Common Equity Tier One capital that is permitted under a transitional arrangement has a reduced percentage. With effect from this year, the percentage is decreased from 95% to 85%.
It is understood that as part of the new securitisation framework, a transitional period will operate in 2019. For securitisations that occurred before 1 January 2019, the requirements of the Capital Requirements Regulation should apply until the end of this year.
The criteria to qualify as a Simple, Transparent and Standardised securitisation have been finalised by the EBA (see guidelines in EBA paper 2018-09) and are effective from 15 May 2019