FSA001: Balance sheet
Q: FSA001 requires us to report all currency figures in thousands. Does the same principle apply to data elements 65A, number of UK retail customers?
A: As data element 65A is not a currency figure, you are required to report this figure in units and not in thousands.
FSA002: Income statements
Q: What period should the first report on FSA002 at end June 2008 cover? We are a BIPRU investment firm with an Accounting Reference Date (ARD) of 30 September. Our existing prudential return submitted at end March 2008 contained the profit and loss data for the quarter to end March.
A: There is an important change in the data reported on FSA002, compared with the data previously provided. FSA002 must be compiled on a 'cumulative' or 'year to date' basis. All BIPRU 125K firms with a 30 September ARD will therefore report their income and expenses for the nine months to end June on their first FSA002 at end June. Similarly, other BIPRU firms with a 31 December ARD will submit the FSA002 covering the first 6 months of 2008.
FSA005: Market risk
Q: Can you please clarify the reporting requirements – the notes relating to FSA005 (SUP16.12.5 - Note 4) seem to imply that I must submit a Market Risk report notwithstanding that our FSA003 shows (at line 93A) a value that is well below the reporting threshold of £50m.
A: The reporting threshold for this data item is £50m and the appropriate regulator will be writing to those firms required to complete this data item. A nil return is not required from firms that have not received such a letter. Gabriel will not display this data item unless a firm is required to report it.
SUP 16.12.5R sets out the basis on which a firm will be required to submit FSA005 (i.e. Note 4) and the firm is expected to monitor its market risk and, if nearing £50m, ensure that it is in a position to be able to report at some future point.
Q: FSA005 requires us to report the results under different currencies. Given Gold is denominated in USD, why would we wish to report the position in other currencies (e.g. GBP) under data element 43?
A: Gold is denominated in USD and therefore should not be reported in any other currency as to do so would be misleading (ie hide FX risk).
FSA007: Operational risk
Q: Can you please clarify the intended reporting requirement for FSA007? Note 3 to SUP 16.12.6R states that the reporting date for this data item is 6 months after a firm’s most recent Accounting Reference Date (ARD) with firms then having to submit the return within 2 months. Under the tables for other Regulated Activity Groups, the note to add on 6 months to the accounting reference date does not exist.
A: The equivalent of note 3 to SUP 16.12.6R should also be carried through to SUP 16.12.12R, 16.12.16R, 16.12.23R and 16.12.26R (and this omission due to an oversight will be rectified in due course). As the data item goes live on 31 August 2008, it means that all firms with an ARD falling at end February 2008 and later will have to complete FSA007 (as long as the firm is not solely on the Basic Indicator Approach, when it does not need to report it).
FSA008: Large exposures
Q: Do I need to inform the appropriate regulator of any large exposures that existed during the quarter but which did not exist at the reporting period end date?
A: If a firm is considering or is likely to have an exposure which exceeds the limits set out in BIPRU 10.56R and BIPRU 10.5.8R, or has one when its Capital Resources are recalculated, then it must advise the supervisor of this in writing without delay. On FSA008, the firm will only be required to report those exposures which equal or exceed 10% of the firm's Capital Resources at the reporting date; any previously large exposures during the quarter that are not large on the reporting date should not be included in the data item.
Q: How should exposures under the institutional exemption (BIPRU 10.6.32R) be reported?
A: Any exposures to non-institutions must go in the ‘non-exempt’ column. For firms without a waiver allowing exposures in excess of 100% LECB, report exposures to institutions up to 75% LECB in the ‘exempt’ column. Any exposures beyond this to institutions should go into the relevant ‘non-exempt’ columns. If the total exposure is greater than the EUR150m upper bound, report the % up to this bound minus 25% in the ‘exempt’ column, and the remaining exposures in the ‘non-exempt’ column. Firms with a waiver allowing them to have exposures in excess of 100% LECB should report exposures to institutions in the ‘exempt’ column up to the waiver limit minus 25%. For example, if the waiver allowed exposures of 150%, 125% would go into the ‘exempt’ column.
Q: How should exposures under the sovereign LE waiver (BIPRU 10.6.35R) be reported?
A: Report up to the sovereign large exposures waiver limit minus 25% in the ‘exempt’ column. The remainder should be reported in the ‘non-exempt’ column.
Q: Must we submit a 'nil' return if we do not have any large exposures at the end of the reporting period?
A: Yes. All firms must submit a large exposures report even if there are no large exposures at the reporting date. Data element 6A requires firms to confirm that they have notified the appropriate regulator in all the cases that they should have done.
Q: We are a BIPRU 50K firm and report on FSA003 (Capital Adequacy) half yearly. Do we also complete FSA008 half yearly?
A: Limited Licence and Limited Activity firms are exempt from the rules in BIPRU 10 and therefore are not required to complete FSA008. Full Scope firms must complete FSA008 quarterly, regardless of whether, as 50K firms, they submit FSA003 half-yearly.
Q: Is there a standard basis on which a firm should monitor its Large Exposures?
A: We recognise that some firms will recalculate their capital resources on regular basis and will monitor large exposures against these changing figures, while others will monitor their large exposures during a quarter based on the capital resources derived from their last FSA003 until such time as their next FSA003 is completed. Either of these approaches is acceptable.
Q: Can you please advise what capital resources figure should be used when completing the Large Exposures return for a UK Consolidation Group?
A: For consolidated reports at calendar quarters when no FSA003 is submitted, the firm has flexibility to choose either to use the previously reported capital resources from its previous FSA003, or to recalculate the figure (either on a regular basis or at the reporting date). Firms should adopt a consistent approach. Our intention is to give greater flexibility to firms by not being specific and forcing them down a specific route.
FSA015: Sectoral information
Q: What is FSA015 and who should complete it?
A: This data item is to be completed by banks and building societies and provides the FCA and PRA with information on the credit quality of a firm's portfolio, enabling us to assess potential threats to the firm's viability. Data Element 1A-G to 11A-G - Balance of accounts - in arrears/default by band (1.5% to 2.5%, 2.5% to 5%, 5% to 7.5%, 7.5% to 10% and more than 10%).
Q: How do I report arrears which are less than 1.5% of the balance?
A: If the arrears are less than 1.5%, the firm does not have to report them at all.
Q: What is the submission period allowed for FSA015? PS 07/23 states that this data item is required to be submitted within 30 business days but SUP 16.12.7R shows the data item required within 20 business days.
A: The submission period as stated in the Policy Statement will apply, ie 30 business days. The Handbook will be updated in due course to reflect the fact the submission should be 30 business days.
FSA017: Interest rate gap
Q: What is the position for reporting at UK consolidation group level? There seems to be a difference between PS 06/10 which states that this data item is required to be submitted at UK consolidation group level only in certain circumstances and SUP 16.12.5R.
A: A footnote will be added to the requirement for FSA017 in SUP 16.12.5R to clarify that this data item need only be completed at the UK consolidation group level for members of UK integrated groups or wider integrated groups. However, UK consolidation groups that do not have UK integrated groups or wider integrated groups will still have to complete this at both the solo/unconsolidated and UK consolidation group levels. This will be consistent with the intention set out in PS 06/10 (following paragraph 6.3).
Q: What discount rate should be be used for row 43 of data item 17?
A: No standard discount rate is prescribed. It is up to the firm to select a risk adjusted yield curve that best represents their business book.
FSA018: Large exposures (UK integrated groups)
Q: Does a firm that is not intending to notify the FCA under BIPRU 10.11.1R (to apply BIPRU 10.7 or BIPRU 10.8) have to complete FSA018?
A: No. It only applies to those firms that have given notice where that notice is still in operation.
Q: Is reporting of all Wider Integrated Group (WIG) exposures required regardless of their size at the reporting date?
A: If the WIG's exposure to a diverse block is less than 10% of the group capital resources under BIPRU 10.8.13R at the reporting date, then it should not be reported on FSA018. However, if all exposures were less than 10%, a zero return would still be required.
FSA030: Profit and loss account
Q: What period should the first report on FSA030 at end August 2008 cover? We are a Securities and Futures firm with an Accounting Reference Date (ARD) of 28 February. Our existing prudential return submitted at end June 2008 contained the profit and loss data for the quarter to end May.
A: There is an important change in the data reported on FSA030, compared with the data previously provided.
FSA030 must be compiled on a 'cumulative' or 'year to date' basis. All firms with a 28 February ARD will therefore report their income and expenses for the 6 months to end August on their first FSA030 at the end of September.
FSA045: IRB portfolio risk
Q: Is it possible for us to report to you the relevant data in the bands that we currently use (i.e. to 4 decimal places)? FSA045 states that reported PD bands should be 'mutually exclusive and numerically sequential'. It also requires these to be stated to 3 decimal places. We previously agreed with the FCA to use PD/EL ranges to 4 decimal places.
A: Following a review of this issue, we intend to remain with 3 decimal places on FSA045. We accept that this will result in a reduced level of precision.