• Question ID: 2018/0053
• Date of publication: 20/08/2018
• Subject matter: General clarifications

Question

Sometimes, throughout the Manual, phrases like “in principle”, “in general” and “as a general rule” are used when discussing reporting instructions. Could you please clarify the qualification of such instructions?

Answer

Please note that with the aim of providing detailed information and guidance concerning AnaCredit reporting requirements as set out in the AnaCredit Regulation, the Manual, rather than thoroughly analysing and presenting all possible scenarios and outcomes, only refers to a basic idea or rule that explains or controls how instruments are or work. To this end, throughout the instructions, phrases like “in principle”, “in general”, “as a general rule” and “typically” are used to indicate that a certain assumption usually holds, but not always, meaning that other possibilities are not excluded.

For example, Section 4.4.10 in Part II of the Manual states that for some types of instruments, “non-applicable” is in principle reported in the data attribute “off-balance-sheet amount” as these instruments do not intrinsically link with an off-balance-sheet amount. Clearly, the phrase “in principle” only indicates that the data attribute may not apply for certain types of instruments. However, the data attribute may apply and, if it does, a suitable value, other than “non-applicable”, should be reported in the data attribute.

Another example is the guidance concerning the “type of protection value” as provided in Table 110 in Part II of the Manual, where it is clearly indicated that the table merely “provides an indication of the type of protection value that would typically be expected for a given type of protection”. Consequently, in no case should banks read the instructions as meaning that all other possibilities are excluded.

In the same vein, all examples provided throughout the Manual should only be seen as an illustration of one possible scenario, which does not rule out any other possibilities; if, in an example, a data attribute is reported as “non-applicable” for a given type of instrument, this does not imply that this data attribute cannot assume a value other than “non-applicable”.