2020-07-06

Added · Updated

Update of Supervisory Reporting Requirements for Credit Institutions

Circular CSSF 20/745 amends Circular CSSF 14/593 by updating the Annex to align with Regulation (EU) 2020/605, requiring credit institutions to submit the updated FINREP table starting from June 2020. The document maintains notification thresholds for large exposures at an individual level, set at the lowest of 10% of own funds or EUR 25 million for institutions and EUR 12.5 million for other clients. It mandates that credit institutions ensure the accuracy, completeness, and timely transmission of prudential information in XBRL format, subject to administrative penalties for non-compliance. Additionally, the circular specifies that prudential information files must be retained for at least five years and that statutory auditors must verify the appropriateness of data transmission provisions.

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CIRCULAR CSSF 20/745 1/19 Circular CSSF 20/745 Update of Circular CSSF 14/593, as amended by Circulars CSSF 15/613, CSSF 15/621, CSSF 16/640, CSSF 17/663, CSSF 18/678, CSSF 18/685, CSSF 19/715 and CSSF 19/729 on supervisory reporting requirements applicable to credit institutions

CIRCULAR CSSF 20/745 2/19 Circular CSSF 20/745 Re: Update of Circular CSSF 14/593, as amended by Circulars CSSF 15/613, CSSF 15/621, CSSF 16/640, CSSF 17/663, CSSF 18/678, CSSF 18/685, CSSF 19/715 and CSSF 19/729 on supervisory reporting requirements applicable to credit institutions Ladies and Gentlemen,

  1. This circular amends Circular CSSF 14/593, as amended, by adding the latest developments in reporting requirements.
  2. The amendment consists of the update of the Annex (FINREP table to be submitted as from June 2020) following the publication of Regulation (EU) 2020/605 of the European Central Bank of 9 April 2020 amending Regulation (EU) 2015/534, as amended by Regulation (EU) No 2017/1538 of the ECB of 25 August 2017, on reporting of supervisory financial information.
  3. Circular CSSF 14/593 is amended in accordance with the annex to this circular. The annex in question includes the changes brought by this circular to Circular CSSF 14/593 in tracked changes in order to make the reading and comprehension easier. In the current COVID-19 situation, this circular does not include handwritten signatures. Yours faithfully, Claude WAMPACH Director Marco ZWICK Director Jean-Pierre FABER Director Françoise KAUTHEN Director Claude MARX Director General Annex Luxembourg, 6 July 2020 To all credit institutions In case of discrepancies between the French and the English text, the French text shall prevail.

CIRCULAR CSSF 20/745 3/19 Circular CSSF 14/593 as amended by Circulars CSSF 15/613, 15/621, 16/640, 17/663, 18/678, 18/685, 19/715, and 19/729 and 20/745 Re: Supervisory reporting requirements applicable to credit institutions Ladies and Gentlemen,

  1. The purpose of this circular is to remind and inform credit institutions of recent and future developments regarding supervisory reporting. I) APPLICABLE REPORTING TABLES
  2. The European Commission published on 28 June 2014 in the Official Journal of the European Union, Commission Implementing Regulation (EU) No 680/2014 of 16 April 2014 laying down implementing technical standards with regard to supervisory reporting of institutions according to Regulation (EU) No 575/2013 of the European Parliament and of the Council (hereinafter, the "CRR"). Implementing Regulation (EU) No 680/2014 entered into force on the day following its date of publication and is directly applicable in the EU Member States without transposition into national law. Amendments to Implementing Regulation (EU) No 680/2014 are published in the Official Journal of the European Union. A list of the amendments to Implementing Regulation (EU) No 680/2014 is published for information purposes in the document “reporting requirements for credit institutions” by the CSSF. Implementing Regulation (EU) No 680/2014, as amended (hereinafter "ITS Regulation"), lays down uniform requirements in relation to supervisory reporting (hereinafter "common European reporting"), in accordance with the requirements of the CRR, for the following areas: • own funds requirements and financial information (Article 99 of the CRR); • losses stemming from lending collateralised by immovable property (Article 101(4)(a) of the CRR); • large exposures and other largest exposures (Article 394(1) of the CRR); • leverage ratio (Article 430 of the CRR); • liquidity coverage requirements and net stable funding requirements (Article 415 of the CRR); • asset encumbrance (Article 100 of the CRR). The common European reporting, except for the requirements on financial information, shall be drawn up on an individual basis and, where appropriate, on a consolidated basis, as defined in the CRR. Luxembourg, 6 July 202020 August 2019 To all credit institutions

CIRCULAR CSSF 20/745 4/19 Financial information shall be drawn up on a consolidated basis: • by all credit institutions that prepare their consolidated accounts in conformity with the International Accounting Standards (IFRS) (Article 99(2) of the CRR), except for the credit institutions referred to in the Q&A 2013_119 published by the EBA and • by all the other credit institutions subject to prudential supervision by the CSSF on a consolidated basis in accordance with Article 99(3) of the CRR. To report the reporting items, as set out above, the assessment is carried out in accordance with the International Accounting Standards (IFRS) pursuant to Article 24(2) of the CRR. 3. The requirements on financial information on an individual basis are set by the national authorities, as these requirements are not covered by the scope of the CRR. In 2014, the CSSF decided to apply the financial reporting (FINREP; ITS) with several versions (full, simplified extended and over-simplified) on an individual basis as in the table below and by observing the principle of proportionality: Categories FINREP Version1 Date of first application Significant entities (within the meaning of the SSM) Significant entities which are not part of a significant group Full 31/12/2015 Significant branches established in Luxembourg by a credit institution established in a non￾participating Member State Full 31/12/2015 Significant entities which are part of a significant group Simplified extended 30/06/2016 1 The tables composing the full, simplified extended and over-simplified versions are included in the Annex 1 (FINREP IAS 39) and in Annex 2 (FINREP IFRS 9 as amended according to the taxonomies v2.7 and following).

CIRCULAR CSSF 20/745 5/19 Subsidiaries of significant Luxembourg groups established in a non-participating Member State or third country2 and whose total value of the assets is above EUR 3 billion3. Over￾simplified 30/06/2016 Branches established in Luxembourg by a significant credit institution established in a participating Member State Over￾simplified 30/06/2017 Less significant entities (within the meaning of the SSM) Less significant entities Simplified extended 31/12/2016 Less significant branches established in Luxembourg by a credit institution established in a non-participating Member State and whose total value of the assets is equal or higher than EUR 3 billion9 Simplified extended 31/12/2016 Less significant branches established in Luxembourg by a credit institution established in a non-participating Member State and whose total value of the assets is lower than EUR 3 billion9 Over￾simplified 30/06/2017 Branches established in Luxembourg by a less significant credit institution established in a participating Member State Over￾simplified 30/06/2017 Third-country branches Branches established in Luxembourg by a credit institution established in a third country Simplified extended 31/12/2016 2 The parent institutions located in Luxembourg and institutions controlled by a parent financial holding company or a parent mixed holding company, established in Luxembourg, shall ensure that the supervisory financial information in respect of the subsidiaries established in a non-participating Member State or third country is reported to the CSSF on an individual basis. 3 To this end, the total value of the assets shall be determined according to the criteria laid down in Part IV, Title 3 of Regulation (EU) No 468/2014 (ECB/2014/17).

CIRCULAR CSSF 20/745 6/19 The reporting requirements on financial information above take into account both (i) the CSSF's own needs for the exercise of its functions as national supervisory authority, as well as (ii) the requirements of Regulation (EU) 2015/534 of the ECB of 17 March 2015 on reporting of supervisory financial information (ECB/2015/13), as amended by Regulation (EU) 2017/1538 of the ECB of 25 August 2017 and then by Regulation (EU) No 2020/605 of the ECB of 9 April 2020 (hereinafter "ECB Regulation"). Banks shall at least report the minimum requirements of the category in which they belong (cf. table above). However, the CSSF shall allow the banks that so wish, to transmit the full version instead of the simplified extended version and the full version or simplified extended version instead of the over-simplified version, respectively. If interested, these banks must contact the CSSF. The accounting standard IAS 39 is replaced by IFRS 9 as from 01.01.2018 according to Commission Regulation (EU) 2016/2067 of 22 November 2016. IFRS 9 brings about, in particular, changes to classification and measurement of financial assets, as well as to impairment of financial assets (the standard provides for the impairment of financial assets for expected losses according to three stages). The FINREP reporting framework was amended in order to take into account IFRS 9 (FINREP/IFRS 94 version). The first application date of FINREP/IFRS 9 depends on the closing date of the financial year: (i) The banks which have closed the financial year as at 31 December 2017 shall report their FINREP/IFRS 9 version for the first time as at 31 March 2018. (ii) The banks which have closed the financial year in 2017 but not on 31 December 2017, shall continue to report the FINREP/IAS 39 until the closing of the financial year in 2018. These banks must report the FINREP/IFRS 9 for the first time on the first reference date in 2018 following the 2018 closing date. The FINREP/IAS 39 is no longer required from the moment where a credit institution reports the FINREP/IFRS 9 version. 4 FINREP/IFRS 9 version as adopted by the European Commission in Commission Implementing Regulation (EU) 2017/1443 of 29 June 2017 amending Implementing Regulation (EU) No 680/2014 laying down implementing technical standards with regards to supervisory reporting of institutions according to Regulation (EU) No 575/2013 of the European Parliament and of the Council.

CIRCULAR CSSF 20/745 7/19 The FINREP/ITS reporting on an individual basis shall be prepared according to the requirements set out in the ITS Regulation and in compliance with the IFRS as adopted by the European Union. It must be submitted on an individual basis in the N/L/S versions. 5 Financial information on an individual basis shall be reported according to the reference dates and transmission dates set out in Articles 2 and 3 of the ITS Regulation, on a quarterly, half-yearly or annual basis (in accordance with the specifications laid down in Annex III of the ITS Regulation regarding the date on which the tables should be established). 4. Guidelines on harmonised definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2 of 19 June 2014. The CSSF identifies and informs the banks that need to report the information relating to the funding plans of credit institutions via mail. 5. The reporting tables introduced by the CSSF that are not covered by the common European reporting, shall remain applicable. In brief, the following reporting tables remain applicable: • Reporting information on participating interests and subordinated loans: table B 2.4 updated by Circular CSSF 18/686; • List of head offices, agencies, branches and representative offices: Table B 4.4; • Analysis of shareholdings: Table B 4.5 as updated by Circular CSSF 12/553; • Persons responsible for certain functions and activities: Table B 4.6 as updated by Circular CSSF 18/695 13/576; • Reporting regarding staff expenses (table B 2.5 B) and details on taxes (table B 2.5 E) as updated by Circular CSSF 17/664. 6. As the reporting requirements continue to evolve at European level, the CSSF strongly recommends that banks follow the publications of draft ITS and/or RTS or consultation papers of the EBA on its website. A summary of all the European supervisory reporting requirements is available at the following address: http://www.eba.europa.eu/risk-analysis-and-data/reporting-frameworks 5 Luxembourg credit institutions with branches abroad must draw up the FINREP/ITS reporting on an individual basis in three different versions, one for the sole head office in Luxembourg (version L), the other for the global institution, including branches (version N). In addition, the head office in Luxembourg shall submit the FINREP/ITS reporting of each branch abroad in a different version (separate figures of the branch) (version S). The L and S versions shall be submitted for the first time as at 31 December 2017. Luxembourg credit institutions with no branches abroad, as well as branches of EU credit institutions and branches of non-EU credit institutions established in Luxembourg shall submit the FINREP/ITS reporting on an individual basis in one single version (version L).

CIRCULAR CSSF 20/745 8/19 The CSSF will inform banks of the changes planned in relation to reporting, on a regular basis, by way of the document “Reporting requirements for credit institutions”. II) REPORTING MANUAL AND PLAUSIBILITY CHECKS 7. The CSSF drafted a manual entitled "Reporting requirements for credit institutions" providing an overview of the aforementioned periodical reporting requirements applicable to banks. This document is available at the following address: https://www.cssf.lu/en/supervision/banks/legal-reporting The manual will be updated on a regular basis in order to take account of the reporting developments at European and/or national level. The CSSF also established a document including a list of plausibility checks carried out internally by the CSSF, in addition to the validation rules published by the EBA as well as a list of plausibility checks identified by the ECB. The document is available at the following address: https://www.cssf.lu/en/supervision/banks/legal-reporting In order to be automatically informed of any change of the aforementioned documents, the CSSF recommends that credit institutions subscribe for updates of the section "Reporting" of the CSSF website. III) REPORTING QUESTIONS AND ANSWERS 8. The European Banking Authority (EBA) established the tool "Questions and Answers" (Q&A) on its website. This tool allows credit institutions to ask the EBA questions relating to European regulations, including questions relating to the common European reporting covered by the ITS regulation. The Q&A tool is available at the following address: http://www.eba.europa.eu/single-rule-book-qa The instructions issued by the EBA in its answers within the context of the Q&A shall be complied with when preparing the common European reporting. 9. The CSSF will also publish on its website answers to questions received by the CSSF on the common European reporting, but of national nature. Answers to questions relating to the reporting introduced by the CSSF will also be published at the same place. These "Questions and Answers" are published by the CSSF at the following address:

CIRCULAR CSSF 20/745 9/19 https://www.cssf.lu/en/regulatory￾framework/?entity_type=480&content_type=1483 IV) EXTENSION OF THE NOTIFICATION THRESHOLD FOR INFORMATION RELATING TO "LARGE EXPOSURES" APPLICABLE ON AN INDIVIDUAL LEVEL 10. In order to obtain a complete overview of the risk profile inherent in the activities of a credit institution and to assess the systemic risks these institutions pose for the Luxembourg financial sector, the CSSF maintains the minimum notification thresholds as regards large exposures at an individual level as applicable until 31.12.2013 according to which any loan granted/used greater than or equal to the lowest of the two following amounts: 10% of own funds or EUR 25 million (for “institutions”) and EUR 12.5 million (for “clients other than institutions”). Thus, the information referred to in the tables "Large exposures" (tables6 C28.00 and C29.00, where applicable) are to be provided, on a quarterly basis, according to the following notification threshold: all the exposures whose exposure value7 is greater than or equal to a. 10% of own funds or EUR 25 million for exposures incurred by “institutions”; b. 10% of own funds or EUR 12.5 million for exposures incurred by “clients other than institutions”. This information shall be reported for the first time on 31 December 2014. V) TRANSMISSION OF PRUDENTIAL INFORMATION BY CREDIT INSTITUTIONS TO THE CSSF 11. The common European reporting tables, as described in point 2 of this circular, shall be transmitted to the CSSF in accordance with: • the requirements of the ITS Regulation; 6 Reporting SLAREX 7 This is the amount of the loan granted/used prior to the credit risk mitigation.

CIRCULAR CSSF 20/745 10/19 • the data point model (DPM) and validation rules published by the EBA on its website; • the technical specifications and in XBRL format as described in Chapter 5 of the manual "Reporting requirements for credit institutions"; and • the supplementary plausibility checks carried out internally by the CSSF in addition to the validation rules published by the EBA. The EBA publishes the updates of the DPM and validation rules, on a regular basis, at the following address: https://www.eba.europa.eu/regulation-and-policy/supervisory￾reporting/implementing-technical-standard-on-supervisory-reporting-data-point￾model￾The reporting tables introduced by the CSSF as mentioned in point 4 of this circular, will continue to be transmitted in accordance with the instructions as regards the transmission and validation rules relating thereto, as published during the introduction of these tables. VI) TRANSMISSION OF PRUDENTIAL INFORMATION BY THE CSSF TO THE EUROPEAN PRUDENTIAL AUTHORITIES 12. The CSSF shall transmit the prudential information as defined in the ITS Regulation to the European Banking Authority and the European Central Bank in accordance with the following decisions: • Decision EBA/DC/2015/130 of 23 September 2015 • Decision ECB/2014/29 of 2 July 2014 The transmission dates provided for in the EBA and ECB decisions must be met without exception. Any delay or absence of transmission by the CSSF to the ECB (and the EBA) within the indicated periods will be reported to the governance committees of the ECB and the EBA. In this context, the CSSF established a table reminder procedure: any table which failed to reach the CSSF (or including errors on the closing date for transmission of information8), will systematically be subject to a first reminder letter as from the following day of the transmission deadline. Any table which failed to reach the CSSF (or including errors) on the second day of delay will systematically be subject to a second reminder letter. 8 Prudential information shall be transmitted within the periods provided for: • in the CSSF circulars for the national reporting, as set out in paragraph 4 of this circular; • in Article 3 of the ITS Regulation for the common European reporting.

CIRCULAR CSSF 20/745 11/19 VII) QUALITY OF PRUDENTIAL INFORMATION 13. The information transmitted to the CSSF serves as a basis for the analysis of the developments in the banking risks incurred by credit institutions at national level, but also at European level. Consequently, the information transmitted shall be established most accurately and be of the highest quality within the deadlines set by the regulations. Credit institutions shall verify the arithmetic and qualitative accuracy, the completeness of the data as well as compliance with the European validation rules and compliance with the plausibility rules published by the CSSF prior to the data transmission to the CSSF. The CSSF must receive the reporting tables without validation errors, technical errors or other quality defects at the deadline dates, as provided for in the regulations. The management of the credit institutions must ensure compliance with the transmission deadlines, the accuracy, quality and completeness of the information provided to the CSSF. Any offence in this respect falls within the regime of administrative penalties provided for in Directive 2013/36 (CRD IV) (cf. Article 67(1)(e)). The CSSF released a test environment allowing the credit institutions to submit to the CSSF test reporting files in order to receive feedback on the validation results. Further details on this subject are available in Chapter 5, Section 2, 2.2 of “Reporting requirements for credit institutions”. The use of the test environment is not compulsory. Each credit institution may decide to use it or not. However, on the closing date of the transmission provided for in the regulations, the credit institution must have sent to the CSSF at least one production (production with a code ‘N’ or ‘D’) of each reporting table. Consequently, any absence of production leads to non￾compliance with the reporting requirements. In case of challenge to a plausibility rule of the CSSF, the credit institution must inform the CSSF by email at the following address: ReportingBanques@cssf.lu. In case of challenge of a validation rule of the EBA, the credit institution must submit a Q&A to the EBA. A copy of the Q&A submitted to the EBA and the Q&A number assigned by the EBA shall also be submitted to the CSSF at the address ReportingBanques@cssf.lu. However, it should be noted that the CSSF will not suspend the challenged validation rule of the EBA at that moment, but only when the EBA has amended the validation rule in question. 14. Moreover, the prudential information files provided to the CSSF shall be kept for a period of at least five years in order to meet any request aiming at the subsequent reconstitution of the provided information.

CIRCULAR CSSF 20/745 12/19 15. The persons responsible for the credit institutions shall establish internal control procedures in order to ensure the implementation of these provisions. 16. The CSSF wishes to stress that the mandate the credit institutions shall entrust to their réviseur d'entreprises (statutory auditor) for the audit of annual accounts shall include the task of verifying the appropriateness and proper implementation of the provisions regarding the data transmission. These controls by the réviseurs d’entreprises must cover the common European reporting as well as the national reporting such as presented in paragraphs 2, 3 and 5 of this circular. VIII) REPEAL OF REPORTING TABLES AND CIRCULARS RELATING THERETO 17. Following the introduction of the common European reporting, the following prudential reporting tables are no longer applicable: Since 1 January 2014 • Foreign currency positions (B 1.2) • Prudential reporting scheme regarding capital adequacy (B 1.4 and B 6.4) • Information on large exposures (B 2.3 and B 6.3) Since 1 July 2014 • • Prudential reporting scheme on financial information on consolidated basis: B 6.1, B 6.6, B 6.2 and B 6.7. Since 1 April 2017 • • Prudential reporting scheme on financial information on individual basis: B 1.1, B 1.6, B 2.1 and B 2.5 (except Parts B and E). 18. The following circulars shall be repealed: • CSSF 14/586 • CSSF 13/570 • CSSF 11/513 • CSSF 10/461 • CSSF 08/344 only repealed for the parts relating to tables B 1.1, B 1.6, B 2.1, B 2.5, (except Parts B and E). B 6.1, B 6.6, B 6.2, B 6.7, B 1.2, B 1.4, B 6.4, B 2.3 and B 6.3 • CSSF 08/381, CSSF 10/450, CSSF 10/493 • CSSF 07/324 • CSSF 07/331 • CSSF 07/319 • CSSF 07/316

CIRCULAR CSSF 20/745 13/19 • CSSF 07/279 • CSSF 06/251 • CSSF 05/227 • IML 93/92. 19. Following the entry into force of the Liquidity Coverage requirement in accordance with Commission Delegated Regulation (EU) 2015/61 of 10 October 2014, table B 1.5 on the liquidity ratio shall be repealed as of 1 October 2015. The following circulars shall be repealed: • • CSSF 07/316 and CSSF 07/331: repealed for the part relating to table B 1.5 • • IML 93/104. 20. For further information concerning this circular, please send an email to ReportingBanques@cssf.lu.

CIRCULAR CSSF 20/745 14/19 Annex 1 FINREP/IAS 39 (until 31 December 2017 except for banks not closing the financial year on 31 December 2017) NAME OF THE TEMPLATE OR OF THE GROUP OF TEMPLATES Over simplified Simplified extended Full PART 1 [QUARTERLY FREQUENCY] Balance Sheet Statement [Statement of Financial Position] 1.1 Balance Sheet Statement: assets 1.2 Balance Sheet Statement: liabilities 1.3 Balance Sheet Statement: equity 2 Statement of profit or loss 3 Statement of comprehensive income Breakdown of financial assets by instrument and by counterparty sector 4.1 Breakdown of financial assets by instrument and by counterparty sector: financial assets held for trading 4.2 Breakdown of financial assets by instrument and by counterparty sector: financial assets designated at fair value through profit or loss 4.3 Breakdown of financial assets by instrument and by counterparty sector: available-for-sale financial assets 4.4 Breakdown of financial assets by instrument and by counterparty sector: loans and receivables and held-to-maturity investments 4.5 Subordinated financial assets 5 Breakdown of loans and advances by product 6 6 Breakdown of loans and advances to non-financial corporations by NACE codes 7 7 Financial assets subject to impairment that are past due or impaired Breakdown of financial liabilities 8.1 Breakdown of financial liabilities by product and by counterparty sector 8.2 Subordinated financial liabilities Loan commitments, financial guarantees and other commitments 9.1 Off-balance sheet exposures: loan commitments, financial guarantees and other commitments given 9.2 9.2 Loan commitments, financial guarantees and other commitments received 10 Derivatives - Trading Derivatives - Hedge accounting 11.1 Derivatives - Hedge accounting: Breakdown by type of risk and type of hedge 12 Movements in allowances for credit losses and impairment of equity instruments Collateral and guarantees received 13.1 13.1 Breakdown of loans and advances by collateral and guarantees 13.2 13.2 Collateral obtained by taking possession during the period [held at the reporting date] 13.3 13.3 Collateral obtained by taking possession [tangible assets] accumulated 14 Fair value hierarchy: financial instruments at fair value 15 Derecognition and financial liabilities associated with transferred financial assets Breakdown of selected statement of profit or loss items 16.1 16.1 Interest income and expenses by instrument and counterparty sector 16.2 16.2 Gains or losses on derecognition of financial assets and liabilities not measured at fair value through profit or loss by instrument 16.3 16.3 Gains or losses on financial assets and liabilities held for trading by instrument 16.4 16.4 Gains or losses on financial assets and liabilities held for trading by risk 16.5 Gains or losses on financial assets and liabilities designated at fair value through profit or loss by instrument 16.6 Gains or losses from hedge accounting 16.7 16.7 Impairment on financial and non-financial assets Reconciliation between accounting and CRR scope of consolidation: Balance Sheet 17.1 17.1 Reconciliation between accounting and CRR scope of consolidation: Assets 17.2 17.2 Reconciliation between accounting and CRR scope of consolidation: Off-balance sheet exposures - loan commitments, financial guarantees and other commitments given 17.3 17.3 Reconciliation between accounting and CRR scope of consolidation: Liabilities 18 Performing and non-performing exposures 19 Forborne exposures PART 2 [QUARTERLY WITH THRESHOLD: QUARTERLY FREQUENCY OR NOT REPORTING]

CIRCULAR CSSF 20/745 15/19 Geographical breakdown 20.1 Geographical breakdown of assets by location of the activities 20.2 Geographical breakdown of liabilities by location of the activities 20.3 Geographical breakdown of main statement of profit or loss items by location of the activities 20.4 20.4 Geographical breakdown of assets by residence of the counterparty 20.5 20.5 Geographical breakdown of off-balance sheet exposures by residence of the counterparty 20.6 20.6 Geographical breakdown of liabilities by residence of the counterparty 20.7 Geographical breakdown by residence of the counterparty of loans and advances to non-financial corporations by NACE codes 21 Tangible and intangible assets: assets subject to operating lease Asset management, custody and other service functions 22.1 22.1 Fee and commission income and expenses by activity 22.2 22.2 Assets involved in the services provided PART 3 [SEMI-ANNUAL] Off-balance sheet activities: interests in unconsolidated structured entities 30.1 Interests in unconsolidated structured entities 30.2 Breakdown of interests in unconsolidated structured entities by nature of the activities Related parties 31.1 31.1 Related parties: amounts payable to and amounts receivable from 31.2 Related parties: expenses and income generated by transactions with PART 4 [ANNUAL] Group structure 40.1 40.1 Group structure: "entity-by-entity" 40.2 Group structure: "instrument-by-instrument" Fair value 41.1 Fair value hierarchy: financial instruments at amortised cost 41.2 Use of the Fair Value Option 41.3 Hybrid financial instruments not designated at fair value through profit or loss 42 42 Tangible and intangible assets: carrying amount by measurement method 43 43 Provisions Defined benefit plans and employee benefits 44.1 Components of net defined benefit plan assets and liabilities 44.2 Movements in defined benefit plan obligations 44.3 Memo items [related to staff expenses] Breakdown of selected items of statement of profit or loss 45.1 Gains or losses on financial assets and liabilities designated at fair value through profit or loss by accounting portfolio 45.2 Gains or losses on derecognition of non-financial assets other than held for sale 45.3 Other operating income and expenses 46 Statement of changes in equity

CIRCULAR CSSF 20/745 16/19 Annex 2 FINREP/IFRS 9 (as from 1 January 2018, except for banks not closing the financial year on 31 December 2017) then according to the EBA taxonomy v2.9 (as from 1 June 2020) NAME OF THE TEMPLATE OR OF THE GROUP OF TEMPLATES Over simplified Simplified extended Simplified 9 Full PART 1 [QUARTERLY FREQUENCY] Balance Sheet Statement [Statement of Financial Position] 1.1 Balance Sheet Statement: assets 1.2 Balance Sheet Statement: liabilities 1.3 Balance Sheet Statement: equity 2 Statement of profit or loss 3 Statement of comprehensive income Breakdown of financial assets by instrument and by counterparty sector 4.1 Breakdown of financial assets by instrument and by counterparty sector: financial assets held for trading 4.2.1 Breakdown of financial assets by instrument and by counterparty sector: non-trading financial assets mandatorily at fair value through profit or loss 4.2.2 Breakdown of financial assets by instrument and by counterparty sector: financial assets designated at fair value through profit or loss 4.3.1 Breakdown of financial assets by instrument and by counterparty sector: financial assets at fair value through other comprehensive income 4.4.1 Breakdown of financial assets by instrument and by counterparty sector: financial assets at amortised cost 4.5 Subordinated financial assets 5.1 Breakdown of non-trading Loans and advances by product 6.1 Breakdown of loans and advances other than held for trading to non-financial corporations by NACE codes 7.1 7.1 Financial assets subject to impairment that are past due Breakdown of financial liabilities 8.1 Breakdown of financial liabilities by product and by counterparty sector 8.2 Subordinated financial liabilities Loan commitments, financial guarantees and other commitments 9.1.1 Off-balance sheet exposures: loan commitments, financial guarantees and other commitments given 9.2 Loan commitments, financial guarantees and other commitments received 10 Derivatives – Trading and economic hedges Derivatives - Hedge accounting 11.1 Derivatives - Hedge accounting: Breakdown by type of risk and type of hedge 11.3 Non-derivative hedging instruments: Breakdowns by accounting portfolio and type of hedge 11.4 Hedged items in fair value hedges Movements in allowances and provisions for credit losses 12.1 Movements in allowances and provisions for credit losses 12.2 Transfers between impairment stages (gross basis presentation) Collateral and guarantees received 13.1 Breakdown of collateral and guarantees by loans and advances other than held for trading 13.2.1 Collateral obtained by taking possession during the period [held at the reporting reference date] 13.3.1 Collateral obtained by taking possession [tangible assets] accumulated 14 Fair value hierarchy: financial instruments at fair value 15 Derecognition and financial liabilities associated with transferred financial assets 9 The simplified version corresponds to the simplified version of the ECB Regulation. It is not a version to be transmitted to the CSSF. This column is only included for information purposes.

CIRCULAR CSSF 20/745 17/19 Breakdown of selected statement of profit or loss items 16.1 Interest income and expenses by instrument and counterparty sector 16.2 16.2 Gains or losses on derecognition of financial assets and liabilities not measured at fair value through profit or loss by instrument 16.3 Gains or losses on financial assets and liabilities held for trading and trading financial assets and trading financial liabilities by instrument 16.4 16.4 Gains or losses on financial assets and liabilities held for trading and trading financial assets and trading financial liabilities by risk 16.4.1 Gains and losses on non-trading financial assets mandatorily at fair value through profit or loss by instrument 16.5 Gains or losses on financial assets and liabilities designated at fair value through profit or loss by instrument 16.6 Gains or losses from hedge accounting 16.7 16.7 Impairment on financial and non-financial assets 16.8 Other administrative expenses Reconciliation between accounting and CRR scope of consolidation: Balance Sheet 17.1 Reconciliation between accounting and CRR scope of consolidation: Assets 17.2 Reconciliation between accounting and CRR scope of consolidation: Off-balance sheet exposures - loan commitments, financial guarantees and other commitments given 17.3 Reconciliation between accounting and CRR scope of consolidation: Liabilities 18 Information on performing and non-performing exposures Information on performing and non-performing exposures 18.1 Inflows and outflows of non-performing exposures - loans and advances by counterparty sector 18.2 Commercial Real Estate (CRE) loans and additional information on loans secured by immovable property 19 Forborne exposures PART 2 [QUARTERLY WITH THRESHOLD: QUARTERLY FREQUENCY OR NOT REPORTING] Geographical breakdown 20.1 Geographical breakdown of assets by location of the activities 20.2 Geographical breakdown of liabilities by location of the activities 20.3 Geographical breakdown of main statement of profit or loss items by location of the activities 20.4 Geographical breakdown of assets by residence of the counterparty 20.5 Geographical breakdown of off-balance sheet exposures by residence of the counterparty 20.6 Geographical breakdown of liabilities by residence of the counterparty 20.7.1 Geographical breakdown by residence of the counterparty of loans and advances other than held for trading to non-financial corporations by NACE codes 21 Tangible and intangible assets: assets subject to operating lease Asset management, custody and other service functions 22.1 22.1 Fee and commission income and expenses by activity 22.2 Assets involved in the services provided Loans and advances: additional information 23.1 Loans and advances: Number of instruments 23.2 Loans and advances: Additional information on gross carrying amounts 23.3 Loans and advances collateralised by immovable property: Breakdown by LTV ratios 23.4 Loans and advances: Additional information on accumulated impairments and accumulated negative changes in fair value due to credit risk 23.5 Loans and advances: Collateral received and financial guarantees received 23.6 Loans and advances: Accumulated partial write-offs Loans and advances: Flows of non performing exposures, impairment & write offs since the end of the last financial year 24.1 Loans and advances: Inflows and outflows of non-performing exposures 24.2 Loans and advances: Flow of impairments and accumulated negative changes in fair value due to credit risk on non-performing exposures 24.3 Loans and advances: Write-offs of non-performing exposures during the period Collateral obtained by taking possession and execution processes 25.1 Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E): Inflows and Outflows 25.2 Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E): Type of collateral obtained 25.3 Collateral obtained by taking possession classified as Property Plant and Equipment (PP&E) 26 Forbearance management and quality of forbearance PART 3 [SEMI-ANNUAL] Off-balance sheet activities: interests in unconsolidated structured entities

CIRCULAR CSSF 20/745 18/19 30.1 Interests in unconsolidated structured entities 30.2 Breakdown of interests in unconsolidated structured entities by nature of the activities Related parties 31.1 31.1 Related parties: amounts payable to and amounts receivable from 31.2 Related parties: expenses and income generated by transactions with PART 4 [ANNUAL] Group structure 40.1 Group structure: "entity-by-entity" 40.2 Group structure: "instrument-by-instrument" Fair value 41.1 Fair value hierarchy: financial instruments at amortised cost 41.2 Use of the Fair Value Option 42 42 Tangible and intangible assets: carrying amount by measurement method 43 43 Provisions Defined benefit plans and employee benefits 44.1 Components of net defined benefit plan assets and liabilities 44.2 Movements in defined benefit plan obligations 44.3 Memo items [related to staff expenses] 44.4 Staff expenses by category of remuneration and category of staff Breakdown of selected items of statement of profit or loss 45.1 Gains or losses on financial assets and liabilities designated at fair value through profit or loss by accounting portfolio 45.2 Gains or losses on derecognition of non-financial assets other than held for sale and investments in subsidiaries, joint ventures and associates 45.3 Other operating income and expenses 46 Statement of changes in equity 47 Average duration and recovery periods

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