Bank Reporting Forms, Definitions and Validations
Form ER - Frequently Asked Questions
This is a selection of the most frequently asked questions by banks required to report the new effective interest rates return (Form ER), along with answers given by the Bank. The contents will be updated on an ongoing basis. If you require any further assistance please contact us.
Netting
Legal right of set-off
Pooled credit/debit balances
New business
Coverage
Calculation
Loan facilities
Short-term household mortgages
Capitalised interest
Overnight deposits/loans
Restructuring of non-performing loans
Traded loans
Other
Accounts with credit and debit facilities
Interest/non-interest bearing credit card lending
Overseas credit card transactions
Checks against balance sheet returns
Cash ISAs
Reporting date
European (ECB) requirements
Calculation of column C
Irregular interest on saving accounts
| Q. | Are effective interest rates calculated on an IFRS basis? |
| A. | Effective interest rates are to be reported as defined by the Yellow Folder rather than under IFRS methodology. Certain aspects of the IFRS methodology would potentially have significant implications for the Form ER definitions and the integrity of reported data. In particular, the IFRS standard for interest measurement uses an ‘effective yield’ concept which amortises fees and expenses that are integral to the return on instrument over its expected life. Thus some items which we currently classify as fees would be absorbed within the interest columns under IFRS. This would constitute a significant change to the reporting guidance, and would have implications for the interpretation of the data. The Bank would be prepared to consider bringing its definitions more into line with IFRS if all reporting institutions agreed to move to this basis at the same time. However, a majority of banks preferred to continue to report on the current basis when this issue was last discussed, in late 2007. For more detail on reporting and IFRS please see the paper titled International Financial Reporting Standards: A Review of Issues likely to impact on MFSD's data via the link http://www.bankofengland.co.uk/statistics/reporters/index.htm |
| Q. | Can you please advise me on reporting trading book assets in the ER return? |
| A. | The interest accrued on the nominal value of the secondary market loan should be reported on Form ER and also on Form PL. Please note that the interest should not be regarded as trading income for reporting on PL. |
| Q. | Some credit and debit balances are subject to a legal right of set-off, and are reported net in the balance sheet returns. How should they be reported in the ER return? |
| A. | The primary objective of the ER return is to achieve the most accurate calculation of effective interest rates. Checks against other returns are of secondary importance. In this situation the most accurate rates will be achieved by reporting gross average balances and gross interest accruals, and this is our preference. However, we are aware that in certain cases this may not be possible, and we will allow such balances to be reported net if gross information is unavailable. In such cases the interest accruing on the net balances should be reported. |
| Q. | Clients of some banks are able to "pool" credit and debit balances in different locations, sometimes outside the UK, before applying a net interest amount. In some cases these balances are physically transferred each day and the interest is posted to that account. In other cases, the clients' balances remain in their original location, and the net interest amount is applied to one account. In each case net balances are reported to the Bank on other returns. Please advise on appropriate treatment for the ER. |
| A. | Again, if banks are able to report gross balances and accrued interest to the original economic sector, please do so, with the exception of those external to the UK (which are excluded since the ER is restricted to sterling business with UK residents). If not, reporting banks should contact the Bank of England for further advice. |
| Q. | What does new business cover? | |
| A. | The ER definitions (December 2002) state that new business is defined as "any new deposit or loan transacted during the reporting month between the bank and its customers. This includes business with existing as well as new customers, additions to existing deposits or loans as well as new accounts, and rollovers of existing corporate loans". This is consistent with ECB requirements of euro-area countries and consists broadly of:
In response to comments from reporting banks (including at the 31 March 2003 briefing seminar), balanced with monetary policy users' needs, this has been limited to:
This narrower requirement does not prevent reporting banks retaining the existing, broader, definition if they prefer. Banks are expected to inform the Bank of England of the exact coverage adopted. Banks should be aware that, should the UK join the single currency, they would be bound by ECB requirements. As shown on the form, the range of instruments for which new business rates are required is itself limited to:
| |
| Q. | How are new business interest rates to be calculated? | ||||||||
| A. | Outstanding business interest rates must be derived as a function of average daily balances and interest flows, as documented in the ER definitions. For interest rates on new business reporting banks may choose one of two options: |
||||||||
| (a) | As the function of new deposits (or loans) and the first day's interest accrued. For each new business transaction this involves recording the new deposit (loan) and the one day's interest accrual. Column A would be calculated as the sum of all new deposits (loans) divided by the number of days in the month. Column B would be the sum of the one-day interest accruals recorded for each new deposit (loan). Column D is the sum of new deposits (loans) during the month. Column C would be calculated in the usual way, ie: |
||||||||
| C | = | Column B | X | No. of days in year (365) | X | ||||
| 100 | |||||||||
| Column A | No. of days in month | ||||||||
| (b) | As the weighted average interest rate on new deposits (loans) during the month, input directly into Column C. This is calculated by multiplying each new deposit (loan) by the (annualised) interest rate applicable on the transaction date, and dividing by the sum of new deposits (loans) during the month. In this case Columns' A and B would be left blank. Column D is the sum of new deposits (loans) during the month. |
||||||||
| Q. | A commercial loan facility is set up and the interest rate agreed. Is this new business? |
| A. | A facility in itself is not new business. New business arises upon the advancement of the loan. |
| Q. | When a short-term discounted rate on a household mortgage matures, the borrower may (a) transfer, or remortgage, the outstanding loan to a new (often also short-term) product or (b) allow the loan to be automatically transferred to the bank's standard variable (or equivalent) rate. A remortgage may be with the existing, or with a new, lender. Do these transfers constitute new business? |
| A. | (a) Yes. The borrower has consciously made a new interest rate agreement. |
| Q. | Is capitalised interest new business? |
| A. | No. |
| Q. | Are overnight loans/deposits regarded as new business? |
| A. | Overnight deposits and overdrafts are not covered in the new business part of the ER, mainly because the average rate is unlikely to differ from the average rate for outstanding business. Overnight loans, other than overdrafts, should be included as new business, assuming they are not automatic extensions of previous loans. |
| Q. | Should restructured non-performing loans be included as new business? |
| A. | No. The objective of new business interest rates is to identify latest rates obtained by clients making new investment and borrowing decisions. Such restructuring is likely to be instigated by the bank, and not the client. |
| Q. | Are traded loans to be included as new business? |
| A. | No. Traded business, by definition, is agreed between two trading counterparties. It involves no renegotiation of the original agreement with the depositor/borrower. |
| Q. | How should we treat accounts ( for example, current accounts with overdraft facilities) which can fluctuate between credit and debit balances? |
| A. | The credit and debit balances, with their applicable interest accruals, should be treated separately. While in credit these are deposits, and while in debit they are loans (usually overdrafts). |
| Q. | When is a credit card account non-interest bearing? |
| A. | Any account on which no interest has been applied during the reporting period shall be classified as non-interest bearing. This will include clients who regularly repay their complete balance before interest becomes payable, and those on interest-free incentive arrangements. All other accounts should be classified as interest bearing in that period, and the total interest applied in the month should be included in Column B. In giving this advice the Bank accepts that the interest applied will include an element of backdated interest relating to purchases in earlier periods. We expect the aggregate effects of this anomaly to offset from month to month. |
| Q. | Should balances and interest arising from overseas or non-sterling credit card transactions by UK residents be included? |
| A. | Yes. The way clients use the loan is not relevant (borrowers taking an unsecured personal loan could equally use it to make overseas or non-sterling purchases). The important factor is that the bank is lending in sterling to a UK resident client. |
| Q. | Will checks against relevant items on balance sheet returns be made each month? |
| A. | There are no validations between the ER and balance sheet returns. The comparable balance sheet items listed in the ER definitions are a guide to the relevant instrument/sector classification. These classifications are consistent. The Bank will periodically compare average balances reported on the ER with equivalent spot balances reported on balance sheet returns, but these comparisons can only be indicative. |
| Q. | Cash ISAs are reported as time deposits on balance sheet returns. How should they be treated on the ER? |
| A. | Sector and instrument classification is consistent between the ER and other Bank of England returns. Cash ISAs should be classified as time deposits on the ER. |
| Q. | Is the reporting date the same for electronic and paper reporters? |
| A. | Yes, the 13th working day. |
| Q. | Are banks in other European countries being asked to supply equivalent information to their Central Banks? |
| A. | Effective interest rates provide important information to UK monetary policy decision makers. The ER return is designed to meet these monetary policy needs, while minimising changes necessary if/when the UK enters the euro-area. Each euro-area National Central Bank (NCB) has been legally required to supply interest rate information to the European Central Bank (ECB) on a monthly basis since February 2003. However, the ECB regulation allows individual NCBs some flexibility in selecting reporting institutions, and in the methodology for calculating average interest rates. |
| Q. | Should column C be calculated from rounded or unrounded figures in columns' A and B? |
| A. | Column C should be calculated from unrounded data in columns' A and B. Figures in columns' A and B should rounded after column C has been calculated, and before the ER return is submitted. |
| Q. | On some household savings products interest does not accrue, since it's level is unknown until a later date. Examples include equity-linked deposits where the interest depends on the performance of shares, and bonus accounts which reward customers with higher interest and/or bonuses for limiting the number of withdrawals. How should interest of these products be applied on the ER return? |
| A. | Where banks are unable to accrue interest flows on a monthly basis interest should be included on the ER return in the period in which it is applied. This treatment is consistent with the PL return. |
Last updated: 28 February 2008
