Bundesbank published the methodology for identifying institutions with reduced reporting requirements under AnaCredit regulation (Regulation 2016/867). Bundesbank has used data, as of December 31, 2020, from the monthly balance sheet statistics to identify the small institutions, in line with the discretion specified in the AnaCredit Regulation.
To ensure proportionality of reporting obligations, Article 16(1) of the AnaCredit Regulation grants national central banks the discretion to exempt, or partially exempt, certain reporting agents from some reporting requirements. In the case of small reporting agents subject to derogations, the relevant national central bank will determine the reporting agents to which derogations apply and the requirements that the reporting agents should meet to satisfy the ECB reporting requirements for AnaCredit. For each reporting member state, there is scope in the AnaCredit Regulation to grant such derogations to a subset of reporting agents, provided that the total amount of loans reported pursuant to the BSI Regulation (Regulation 1071/2013) by such reporting agents does not exceed 2% of the overall amount of loans reported pursuant to the BSI Regulation in a given reporting member state. Bundesbank grants the institutions classified as small reporting agents a derogation in the form of reduced reporting requirements. Bundesbank informs these institutions accordingly. In the event of a merger, the reduced reporting requirements of the acquiring institution shall apply to the entire (new) institution until further notice.
The evaluation of data from the monthly balance sheet statistics, as of December 31, 2020, showed that the average of the five largest "small" institutions (that is, those five institutions that are still below the 2% limit and thus still fall under the reporting relief) in terms of the total outstanding loan amount is EUR 517.4 million. The following items from the monthly balance sheet statistics are included in the calculation of the total outstanding loan amount of an institution:
- A1 100 05: Book claims on banks (MFIs)
- A1 100 07: Change in the portfolio of banks (MFIs)
- A1 100 09: Balances with central banks
- B1 500 04: Book claims on non-banks
- B1 500 06: Bills of exchange in the portfolio of non-banks
- HV11 130: Compensation claims against the public sector
Related Links (in German)
Keywords: Europe, Germany, Banking, Reporting, AnaCredit, National Discretions, Reduced Reporting Requirements, Bundesbank
Scott is a Director in the Regulatory and Accounting Solutions team responsible for providing accounting expertise across solutions, products, and services offered by Moody’s Analytics in the US. He has over 15 years of experience leading auditing, consulting and accounting policy initiatives for financial institutions.
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