BDE has published two circulars (3/2020 and 2/2020) that amend Circular 4/2017 for credit institutions on public and confidential financial reporting rules. Circular 3/2020 introduces changes on the credit-risk classification of forborne exposures. Circular 2/2020 increases the reporting requirements of banks in respect of non-performing and forborne exposures and foreclosed collateral, supplements the information on operating and administrative expenses, and incorporates minor changes to the data to be reported on leases as a result of the entry into force of IFRS 16 on leases. The circulars will enter into force the day following their publication in the "Official State Gazette."
In response to COVID-19, Circular 3/2020 is intended to allow greater flexibility in applying expert judgment for the credit-risk classification of forborne exposures. Specifically, the new Circular allows rebuttal of the presumption that the granting of these loans would always result in a significant increase in credit risk. Banks may rebut this presumption and classify the loans as performing, if they consider that there has been no significant increase in credit risk, notwithstanding the requirement that they be identified as forborne exposures for their proper monitoring and risk management. This amendment allows the entities subject to Circular 4/2017 to make greater use of the flexibility in the EBA guidelines on the credit risk management practices of credit institutions and the accounting for expected credit losses (EBA/GL/2017/06).
Circular 2/2020 intends to incorporate changes related to the reporting requirements applicable to credit institutions, which were introduced by the Commission Implementing Regulation 2020/429 and ECB Regulation 2020/605. To comply with the ESRB recommendation on closing real estate data gaps, this circular introduces changes to the information required from credit institutions on (commercial and residential) real estate loans. Circular 2/2020 also incorporates the latest developments in IFRS and other standards adopted or approved by EU, simplifies certain reporting requirements for credit institutions, and updates the information required in the different financial statements.
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Effective Date: Official Gazette+1 Day
Keywords: Europe, Spain, Banking, COVID-19, Credit Risk, Reporting, NPL, Forborne Exposures, Expected Credit Loss, IFRS 9, IFRS 16, Leases, EBA, ECB, ESRB, EC, BDE
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