List of Q&As

OPR Details

a)Could you provide an explanation to the reference to Article 5 point (b) (2) iii in paragraph 124 of the COREP instructions (operational risk details template)? b)Is EBA going to publish every year the sum of individual balance sheet totals of all institutions within a Member State or should we ask this information from the national supervisor? c)Article 6 of the ‘Draft ITS on supervisory reporting’ refers to article 4. Is this correct? d)If the ratio of individual balance sheet total on the sum of individual balance sheet totals of all institutions within the same Member State is higher than or equal to 1% over the first reporting period (Q1 2014), some information about operational losses has to be reported. Is this a correct interpretation of the entry criteria mentioned in article 4 of the ‘Draft ITS on supervisory reporting’?

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: 2013_362| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 08/10/2013

Error on ID / Template C01.00 - Own Funds (CA1), row 780

Why row 780 has not the same ID between Excel file (Annex I - Own funds templates) and Word file (Annex II - 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: 2013_349| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 07/10/2013

Distribution in columns 040-070 in Geographical Breakdown

Are the columns 040-070 memorandum items in the same way (the figure should be reported where the obligors would have been reported if those exposures were not in assigned to “in default”) that column 020 is?

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: 2013_347| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 07/10/2013

Memorandum items in credit risk SA

Can you please confirm that the memorandum items in row 290-320 only should be filled in within exposure classes mentioned under point 54 (annex II, 3.2.1) and the Total template? I.e. that those rows should be empty in the exposure classes “in default” and "secured by immovable property”.

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: 2013_346| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 07/10/2013

Allocating the FX differences as a result of subsidiaries' consolidation

Table 46 requires the reconciliation of opening and closing balances for equity account, which is also a requirement under IFRS. Usually banks with foreign subsidiary operations have a separate line item in the IFRS reconciliation reporting to record the effects of FX reconversion of the subsidiaries. The line to account for the FX difference is missing in FINREP table 46. Where should FX differences be reported?

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: 2013_345| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 07/10/2013

Link between table 1.1 and tables 4.1 to 4.4

"The link between table 1.1, ""cash balances at central banks"" and ""other demand"" deposits"" and tables ""4.1 to 4.4"" is not clear to us. (1) On the one hand, table 1.1, line 30 (""cash balances at central banks"") and line 40 (""other demand deposits""), have a detailed breakdown in table 4 according to Annex III. (2) On the other hand, Annex V (part I.12) states that “accounting portfolios”, meaning financial instruments aggregated by valuation rules, as they are delineated in tables 4.1 to 4.4, do not include ""cash and cash balances at central bank"". This statement is supported by the missing rules between table 1.1, line 30 and line 40 and table 4. In our opinion, these two facts represent a contradiction."

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: 2013_339| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

Reporting thresholds - entry and exit criteria

Institution shall start reporting information subject to thresholds from the next reporting reference date where they have exceeded the threshold on two consecutive reporting reference dates. Is our understanding correct that if an institution exceeded the thresholds as of December 31 an September 30 the first reporting should be submitted for the reference date December 31? Institutions may stop reporting information subject to thresholds from the next reporting reference date where they have fallen below the relevant thresholds on three consecutive reporting reference dates. Based on the same methodology we assume that if an institution has fallen below the thresholds as of December 31, September 30 and June 30 no reporting is required as of December 31. 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: 2013_337| Topic: Supervisory reporting - Other| Date of submission: 04/10/2013

Security code if no ISIN code available

If there are no ISIN code or other public codes that uniquely identifies the instrument, what should then be filled in in table F 40.2 column 010?

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: 2013_336| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

Reporting of entity level

In table F 40.01, Annex III, the group structure should be reported entity-by-entity. Question: What is the level of detail required in this table? Approach 1: only subsidiaries Approach 2: subsidiaries of subsidiaries (i.e. all companies in the group) Example: Group XYZ comprises Parent A which owns sub-group B and subgroup C. Both subgroup B and C are part of the CRR base of consolidation. Should the Group XYZ report in table 40.01 only the first level of subsidiary in subgroup B and C (I.e. parent company of sub-groups B and C) or also all companies owned by sub-group B and C?

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: 2013_334| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

Missing LEI code

What should be reported in column 010 in table F 40.01 Annex III and in column 025 in table C 06.00 Annex I, if LEI code is missing for an entity? Should the cell be left empty?

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: 2013_333| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

Where to report Retail card operations, card fees and acquiring fees

In which row should Retail card operations, card fees and acquiring fees be reported in template F 22.01, Annex III (Fee and commission income and expenses by activity)?

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: 2013_331| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

Interpretation of domestic

A bank have the Parent company incorporated in Sweden with branches and subsidiaries abroad within and outside EC. Shall instructions in ITS Annex V §107 for template 20.1, 20.2 and 20.3 be interpreted: · Domestic activities= activities in the country of the Financial Group that submits the report = Sweden? · Domestic activities= activities in the countries of Members states = European Community?

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: 2013_330| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

Reconciliation of assets and liabilities in reinsurance and insurance contracts

A bank has an insurance sub-group with unit-link insurance plans (aka ULIP. ULIPs give the holder the ability to invest in financial instruments and be hold the insurance contract) and traditional life insurance contracts. The insurance sub-group is fully consolidated in the Group (IFRS scope) but not consolidated in the Financial Group (Finrep scope). Shall instructions in ITS Annex V §105, §106 for template 17.1 row 270 and template 17.3 row 170 be interpreted: · Strict: only to be used for insurance contracts, or · Wide: to be used for both insurance contracts and investment contracts (i.e. ULIPs)

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: 2013_329| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 04/10/2013

F 15 Amounts derecognised for capital purposes

We would please like to know in more detail than provided through legal references what information is required in F 15 col. 110 "Amounts derecognised for capital purposes". Should the column comprise the assets treated as securitisation positions that have been deducted from Common Equity Tier 1? In other words, is it referred to those assets that receive the above-mentioned treatment based on CRR articles 243(1.b) and 244(1.b), which allow deduction of the 1250% risk weighted securitisation positions? Thanks in advance.

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: 2013_320| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 03/10/2013

Reporting of notional amount for the derivatives hedging different risks (table 11.1 FINREP)

If the same hedge derivative contract is used in different transactions (i.e. to hedge multiple risks), shall the nominal amounts be reported gross and multiple times (column 030, table 11.1)?

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: 2013_316| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/10/2013

Definition of Custody assets 'entrusted to other entities' (Table 22.2)

Definition of ‘Of which: entrusted to other entities’ (row 090) in Table 22.2. Are only assets held with sub-custodians of the reporting entity reported in row 090?

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: 2013_313| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/10/2013

Reporting of Off Balance Sheet Activities (Table 22.2)

If the reporting entity has the same assets under asset management and also under its custody, can the assets reported in sub-sections of table 22.2 (e.g. ‘Custody assets’, ‘Asset Management’, and ‘Central administrative services for collective investment’) be duplicated?

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: 2013_312| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/10/2013

Reporting currency - Table 40.1

Which reporting currency should be used in table 40.1 Group Structure 'entity-by-entity'? Shall the reporting currency of the each investee (consolidated entities) or the investor (parent) be used?

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: 2013_311| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 01/10/2013

Validation Rules (SEC) - Rule v531_m does not take into account value adjustments on deductions from own funds

Validation rule v531_m does not seem to take into account that as stated in CRR 266(1) deductions from own funds can be reduced by the specific credit risk adjustments made in respect of the exposure leading to the deduction. Column 180 of C 13.00 (CR SEC IRB) reports these deductions as specified in CRR 266(3). Crr 266(3a) in turn refers to CRR 266(1) and (2) for the calculation of the deduction amounts. When there are such specific credit risk adjustments on deductions from own funds, the value in column 180 is reduced accordingly and the sum of columns 170 and columns 180 does not add up to the value of column 190. Should therefore this validation rule not be weakend to {c190}

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: 2013_227| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 10/09/2013

COREP securitisations (crsecirb, crsecsa and crsecdetails)

It is unlcear from the instructions for the COREP which securtisations exposures should be filled in, in which tab (crsecirb, crsecsa and secdetails).

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: 2013_204| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 02/09/2013