If a loan is postponed as part of a general payment moratorium, the postponement does not in itself result in classification as a “forbearance measure” within the meaning of Article 47b of the CRR (see EBA/GL/2020/02, margin no. 11). Similarly, postponement on a case-by-case basis is not always classified as a forbearance measure under Article 47b of the CRR (and in particular paragraphs 240-268 of Part 2 of Annex V of Commission Implementing Regulation (EU) No 680/2014) which would have to be reported in template F 19. This is the case if an institution grants a postponement to an obligor that is not experiencing financial difficulties. The criteria to be applied when determining whether a postponement is to be regarded as a forbearance measure and, in particular, whether an obligor is deemed to be experiencing financial difficulties, are the same criteria, in compliance with the relevant statutory requirements, as those applicable before the COVID-19 crisis. If, based on these criteria, a postponement is not to be regarded as a “forbearance measure” within the meaning of Article 47b of the CRR, it need not be reported in template F 19.

Likewise, if a loan is postponed as part of a general payment moratorium, the postponement does not in itself result in classification as distressed restructuring within the meaning of Article 178(3)(d) of the CRR (see EBA/GL/2020/02, margin no. 11). Under certain circumstances, the postponed loan could be regarded as defaulted within the meaning of Article 178 of the CRR. In such cases, the loan must then be classified as non-performing within the meaning of Article 47a(3)(a) of the CRR and reported as a non-performing exposure in template F 18. For more information, please see the following FAQs:

“General payment moratorium: If a claim for repayment of a loan is postponed as part of a general payment moratorium, is the obligor considered defaulted within the meaning of Article 178 of the CRR?” and ”Credit risks: Do liabilities that have been postponed on a case-by-case basis (e.g. postponement of instalments) have to be regarded as defaulted? When does postponement on a case-by-case basis lead to a deduction from own funds and is this in line with the Minimum Requirements for Risk Management (Mindestanforderungen an das Risikomanagement – MaRisk)?”