Example 2
A non-EEA bank in RAG 1 that also carries on activities in RAG 5
Again, overlaying the RAG 1 reporting requirements with the requirements for a RAG 5 firm gives the following :
RAG 1 requirements (SUP 16.12.5 R)
RAG 5 requirements (SUP 16.12.18A R)
Annual accounts
Annual accounts
Audited accounts of the mixed-activity holding company (note 9)
Solvency statement (note 10)
Balance sheet
Balance Sheet
Income statement
Income statement
Capital adequacy
Capital Adequacy
Credit risk
Market risk
Market risk -supplementary
Operational risk
Large exposures
UK integrated group large exposures
Liquidity (other than stock)
Liquidity - stock
Forecast data
Solo consolidation data
Interest rate gap report
ELMI questions
Non-EEA sub-group
Lending - Business flow and rates
Residential Lending to individuals - New business profile
Lending - Arrears analysis
Mortgage administration - Business profile
Mortgage Administration - Arrears analysis
Analysis of loans to customers
Provisions analysis
Fees and levies
In this case, it is more obvious that the firm's reporting requirement in RAG 1 is not all the data items listed above. However, for the purposes of this exercise, it is the list of potential data items that is important. Thus comparing RAG 1 with RAG 5, the additional reporting requirements are:
(a)Lending - Business flow and rates, where Section D MLAR is required;
(b)Residential Lending to individuals - New business profile, where Section E MLAR is required;
(c)Lending - Arrears analysis, where Section F MLAR is required;
(d)Mortgage administration - Business profile, where Section G MLAR is required;
(e)Mortgage Administration - Arrears analysis, where Section H MLAR is required
(f)Analysis of loans to customers, where section A3 of MLAR is required
(g)Provisions analysis, where Section B2 of MLAR is required; and
(h)Fees and levies, which are not applied across RAGs by virtue of SUP 16.12.3R (1)(a)(iii).
The reporting frequency and submission times for items (a) to (g) above are then derived from the rules applicable to RAG 5 firms in SUP 16.12.18 R.
The fact that the non-EEA bank has no specific data item to complete in respect of the balance sheet and capital adequacy in RAG 1 means that the notional requirement to provide such reports is satisfied by a non-submission. For example, in the case of the balance sheet for a non-EEA bank, this data is not requested as it duplicates data provided to the Bank of England, which is also available to the FSA.