List of Q&As

Provision of data to cover the cost of living

Does the data referred to in Article 8(4) DGSD have to be provided by the credit institution after the date on which the credit institution has become unable to repay deposits? Or is it possible for a DGS to use data which has been provided by the credit institution before the credit institution has become unable to repay? If DGS are expected to use data which is provided after the aforementioned date, does the data have to be provided specifically for calculating the appropriate amount or can/must data be used which is (mainly) provided for making the repayments?

Legal act: Directive 2014/49/EU (DGSD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2016_2907| Topic: Rights of depositors (Eligibility, coverage level, repayable amount, repayment, claim against DGS, depositor information)| Date of submission: 15/09/2016

NSFR calculation - deposits

In the context of the reporting of stable funding (i.e., C 60.00 and C 61.00), we have the following two questions: (1) How should institutions report retail term deposits with a residual maturity of four months but where early withdrawal (i.e., < three months) is possible contingent upon the payment of a penalty that corresponds to the interests due for the time that elapsed between the date of deposit and the date of withdrawal? Are these deposits to be reported in the maturity bucket “within three months” or “between three and 6 months”? (2) Considering the deposits provided under (1), what would be the treatment if these deposits are provided by wholesale customers?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4804| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 25/06/2019

Validation rules v2.8.1

This question refers to the validation rule v5532_m. The prerequisites indicate that template F 04.02.2 triggers this validation rule. Specifically, the prerequisites are : F 06.01 and (F 04.02.1 or F 04.02.2 or F 04.03.1 or F 04.04.1). In the French Gaap environment, only F 04.02.2 is defined as compulsory but not the other templates F 04.XX. For this reason the rule may not be valid in general because all the other files are not produced. For reminder the formula is {F 06.01, r190, c010} = {F 04.02.1, r160, c010} - {F 04.02.1, r160, c020} + {F 04.02.2, r170, c010} - {F 04.02.2, r170, c020} + sum({F 04.03.1, r160, (c015, c030, c040)}) + sum({F 04.04.1, r120, (c015, c030, c040)}) Could it be possible to modify the appliance conditions of this Validation Rule ? Will it be corrected in a further evolution of the EBA VR ? Thanks

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4803| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 21/06/2019

Validation rule v6405_m

Validation rule v6405_m does not calculate right when the credit institution has only T1 capital and no T2 capital. Report is COREP own funds.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4778| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 14/06/2019

Funding plan validation error v6223_m

Can a credit institution submit a funding plan with having an actual reverse repurchase agreement starting position and no projected positions in view of validation error v6223_m (template P01.03)?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions

ID: 2019_4727| Topic: Supervisory reporting - Funding Plans| Date of submission: 17/05/2019

ABCP programme

Does an ABCP programme meet the definition under Article 242(11) of Regulation (EU) No 575/2013 (CRR) as amended by Regulation (EU) 2017/2401 in any case, whether or not the credit risk of the financial assets acquired by the conduit is tranched into different risk categories at the programme level?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4323| Topic: Securitisation and Covered Bonds| Date of submission: 15/10/2018

EBA_v6217-6222 and EBA_v6224-622; EBA_v6230 validation rules (warnings) implementation

Does EBA_v6217-6222 and EBA_v6224-622; EBA_v6230 validation rules (warnings) are correctly implemented and should be applicable for all institutions?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4640| Topic: Supervisory reporting - Funding Plans| Date of submission: 29/03/2019

Benchmark Rates of other currencies than EUR, USD, GBP

Can you kindly confirm: - Currencies other than the three currencies mentioned in Point 3(b) namely EUR, USD and GBP must be compared to the benchmark in the same currency - For currencies that are not captured by LIBOR (e.g. CAD, RON), we should apply the benchmark rates set by the respective organisation (e.g. Romania Three Month Interbank Rate for RON).

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4616| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 21/03/2019

FINREP F01.03, F02 and F46 checks (V1226_m and V0786_m)

The non-xbrl check V1226_m is in contradiction with v0786_m

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4612| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 14/03/2019

Validationrule v5713_s DPM2.8 FINREP F 46.00

Our question relates to EBA validationrule v5713_s which, in our view, is not always applicable. This validation rule applies to the situation where a dividend distribution is done from "Capital"; the first column. In this situation the amount of dividend should be negative in c_010, r_110 of template F46.00. However, there can also be the situation that a stock dividend is converted from Share premium to Capital. In this situation there is a negative amount reported in the second column "Share premium" and there is an equal positive amount in the column "Capital" disclosed. The total change in equity is nil, but there is a shift from Share premium to Capital. In this situation should it be possible to report a positive amount in the column "Capital". Is our understanding correct ?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4591| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/03/2019

Recognition of “unfunded credit risk protection” as CRM, in case of “items associated with particular high risk”

Can “unfunded credit risk protection” reduce the credit risk exposures in case of “items associated with particular high risk”?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_4765| Topic: Credit risk| Date of submission: 05/06/2019

Reporting of contributions to the default fund of a CCP

There seems to be an incoherence between Q&A 2013_209 and the instructions contained in Annex 2 of EBA Implementing Regulation (EU) No 680/2014 regarding the Reporting of contributions to the default fund of a CCP.

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2019_4563| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 19/02/2019

[eba_v1042_m] f16.01

Why the total of the table F16.01.b doesn't follow the rule [eba_v1042_m]? Is this related to negative interest rates?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2018_4434| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 24/12/2018

Closely correlated currencies

How to manage the closely correlated currencies according to Article 354(1) CRR under the standardised approach?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4142| Topic: Market risk| Date of submission: 19/07/2018

ABCP Programme

Does an ABCP programme meet the definition under Article 242(9) of Regulation 575/2013 – or Article 242(11) CRR as amended by Regulation (EU) 2017/2401, which refers to-Article 2(7) in Regulation 2017/2402   when it invests not only in securitisation transactions (i.e. ABCP transaction as defined in Article 2(8) in Regulation 2017/2402) but also in other type of assets?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4324| Topic: Securitisation and Covered Bonds| Date of submission: 16/10/2018

Validation rule on C_05.01 template - V0193_M

Should V0193_M validation rule be deactivated or changed?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2018_4256| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 10/09/2018

Consistency of COREP validations rules e4896_n & e4895_n

Are the COREP EBA validation rules e4896_n & e4895_n consistent with Article 134 (7) of the CRR?

Legal act: Regulation (EU) No 575/2013 (CRR) as amended

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3561| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 13/10/2017

Clarification on what is considered insured deposits

When determining the covered deposits, should netting with customer loans be applied before determining the amount of deposits which are not covered by the DGS?

Legal act: Directive 2014/49/EU (DGSD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2015_2324| Topic: Rights of depositors (Eligibility, coverage level, repayable amount, repayment, claim against DGS, depositor information)| Date of submission: 25/09/2015

Risk weights for the core indicator set

EBA/GL/2015/10 Article 58, bullet point 2 suggests that there is no flexibility of the risk weights when the core risk indicator set are applied (with no additional indicators or any indicators left out). Would it be in compliance with the guidelines to use the core indicator set but to distribute the 25 % flexible weights somewhat different than what article 58, bullet point 2 suggests?

Legal act: Directive 2014/49/EU (DGSD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/10 - Guidelines on methods for calculating contributions to deposit guarantee schemes

ID: 2017_3096| Topic: Funding provisions (financing means, use of funds, borrowing, calculation of contributions)| Date of submission: 12/01/2017

Definition of payee for dynamic linking

Article 5 of the RTS on strong customer authentication and secure communication requires the authentication code to be specific to the amount of the payment transaction and the payee.Does it suffice to include a meaningful part of the identifier into the calculation of the authentication code? For instance, would it suffice to include only numeric characters of the IBAN in the calculation of the authentication code?

Legal act: Directive 2015/2366/EU (PSD2)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2019_4556| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 15/02/2019