List of Q&As

Financial assets impairment

Do impaired financial assets also include the ones that are found to be impaired at the group level or only those individually impaired? More specific, in the financial reporting form F 04.04, the column 020 “Impaired assets [gross carrying amount]” includes only the financial assets impaired on individual basis (with specific allowances for individually assessed financial assets or specific allowances for collectively assessed financial assets)?

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_198| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 02/09/2013

FINREP: Multilateral banks

Is there any list of multilateral banks for FINREP purposes available?

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_138| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 07/08/2013

Cash outflows on other liabilities

What are the general mandatory requirements for clearing, custody and cash management deposits for the beneficial run-off factors of 5%(with deposit insurance scheme) and 25%(without deposit insurance) respectively? How can it be proved that a client is compromised in its operational functioning upon withdrawal of funds within the 30 day horizon? Can you give us an example?

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

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

ID: 2013_480| Topic: Liquidity risk| Date of submission: 01/11/2013

Calculation of own funds requirements for CVA risk on a consolidated basis

How shall the own funds requirement for CVA risk be calculated for consolidated group of institutions?

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

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

ID: 2013_471| Topic: Market risk| Date of submission: 01/11/2013

Eligibility of index CDS hedges in Advanced CVA charge

Please can you confirm whether Basel FAQ 2c7 published in December 2012 on page 19 of BCBS's FAQ (http://www.bis.org/publ/bcbs237.pdf) is applicable under CRR?

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

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

ID: 2013_360| Topic: Market risk| Date of submission: 08/10/2013

LCR outflow to report for shorts under Article 423(4) of Regulation (EU) No. 575/2013 (CRR)

We assume we should be symmetrical in terms of the outflow reported for shorts (to be delivered within 30 days) and the inflows reported for the corresponding short covering trades (reverse repo/stock borrow) that mature within 30 days, since the two transactions are reported gross and independently of each other, and it is the maturity of the reverse repo/stock borrow that gives rise to the need to deliver within 30 days. We believe that the outflow to report under Article 423(4) of the CRR should be weighted consistently in line with reverse repo inflows per Article 425(2)(d): 0% for assets listed under Article 416(1)(a), (1)(b) and (1)(c) At least 15% for assets listed reported under Article 416(1)(d) 100% for any other asset not qualifying under Article 416(1)

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

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

ID: 2013_355| Topic: Liquidity risk| Date of submission: 08/10/2013

20% inflow on assets with an undefined contractual end date

What is the practical interpretation of 20% inflow on assets with an undefined contractual end date?

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

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

ID: 2013_306| Topic: Liquidity risk| Date of submission: 30/09/2013

Reporting of amounts 'representing claims or guaranteed by multilateral development banks'

There appears a possible inconsistency in relation to the reporting of Row 610 on the outflows template 'representing claims on or guaranteed by multilateral development banks' and the corresponding instructions. In particular, the instructions make reference to 'representing claims on, or claims guaranteed by, the Bank of International Settlements, the International Monetary Fund, the European Union, the European Financial Stability Facility, the European Stability Mechanism or multilateral development bank' and not therefore only multilateral development banks. Can the EBA advise whether there is an error in the reporting template or instructions or whether this is indeed intended to be the case?

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_373| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 10/10/2013

Derivatives reporting in stable funding

On page 9 (2.1 - 6) it is stated that the derivatives payables and receivables is to be reported according to regulatory netting rules, not accounting rules, (applicable for both categories), which means that the summation of the categories are not going to be neither the same, nor add up to the total assets. Please clarify the amount to be reported for derivatives, and how the control for templates 60 and 61 will work.

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_348| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 07/10/2013

Reporting frequency for template C17.00 Op risk details

Please elaborate which reporting period that should be included in the semi-annual reporting of template C017.00. According to the Annex II, part 4.2 paragraph 119 this template summarises the information by an institution in the last year. If it should be reported with a semi-annual report, which reporting period should then be included in the reporting as per end Dec resp. end June? Possible way to read this: - The same figures should be reported twice a year (just as template C16.00 contains the same figure for four quarters in row). - Rolling 12 month reporting (i.e. as per end June is 1/7 the previous year until 30/6 the reporting year)

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_285| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 27/09/2013

January and February 2014 figures for the Q1 2014 leverage ratio reporting

Does the leverage ratio Q1 2014 reporting should include January 2014 and February 2014 data

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_266| Topic: Supervisory reporting - Leverage ratio| Date of submission: 19/09/2013

Group solvency template - columns 300 until 340

In order to determine the qualifying own funds for the different own funds elements (Common Equity Tier 1, Additional Tier 1 and Tier 2 capital), according to sub 1 of Articles 84, 85, 86, 87, 89, capital requirements should be taken into account. Suppose, the qualifying own funds of a non-regulated entity within the CRR scope of consolidation should be determined. Is our interpretation correct that, given the fact that no capital requirements exists for a non-regulated entity, the outcome of the calculation of the qualifying own funds of a non-regulated entity according to Articles 84, 85, 86, 87, 89 always equal zero?

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_263| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 18/09/2013

Group solvency template - columns 120, 130 and 140

Annex I of the ITS on reporting (Own funds templates) states that the figures to be reported in column 120 (Own funds) of the Group Solvency template should be equal or equivalent to the own funds reported in row 0010 of the template CA1. We conclude from that, that column 120 of the Group Solvency template should comprise all Tier 1 and Tier 2 capital of the entity the respective row refers to. From Annex I of the ITS on reporting (Own funds templates) we understand that column 130 of the Group Solvency template should reflect instruments (including related retained earnings, share premium accounts and other reserves) that are owned by persons other than the undertakings included in the CRR consolidation. From the same ITS and its reference to Article 87 (i)(b) of CRR we assume that column 140 relates to all own funds instruments of the subsidiary that are included in Common Equity Tier 1, Additional Tier1 and Tier 2 items and the related share premium accounts, the retained earnings and other reserves. We assume that the difference between the figures to be reported in column 120 and 140 of the Group Solvency template is that column 120 reflects all Tier 1 and Tier 2 capital of the entity the respective row refers to, whereas in column 140 only the part of Tier 1 and Tier 2 capital that is included in the consolidated own funds of the reporting entity, should be reported. Could EBA confirm that this assumption is 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_262| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 18/09/2013

Does the "Excess of deduction from AT1 items over AT1 Capital" used for the calculation of the 17.65% threshold include the transitional additions for grandfathered instruments and instruments issued by subsidiaries

When calculating the applicable 17.65% threshold, is the "Excess of deduction from Additional Tier 1 (AT1) items over AT1 Capital" (Article 36(1)(j)of Regulation (EU) No 575/2013 (CRR)) supposed to be adjusted for the transitional adjustments made earlier in the process for grandfathered instruments and instruments issued by subsidiaries?

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_256| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 17/09/2013

COREP templates to be submitted on a semi-annual basis.

The draft ITS (Articles 5(b), 6(b), 8(1)(b), 8(2)(b) and 12) and the CRR mention that OPR details, CR SEC details, Group Solvency and Losses on Immovable Properties templates are to be submitted on a semi annual basis. Can you confirm that the first reporting date for these templates will be 30 June 2014?

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_244| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 13/09/2013

FINREP F13.1 row 010 Loans and advances col. 050 Financial guarantees received

What is the information that should be included in this box? Is it the whole amount of financial guarantees received, or is it the value of those financial guarantees received that are related to loans and advances collateralized by immovable properties or any other in rem guarantee? In other words, if a loan has only financial guarantees, and none of those included in columns 010 - 040, shall that financial guarantee be included in row 010 & column 050?

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_236| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 11/09/2013

FINREP - Contents of templates 7 and 5 - Row "On demand [call] and short notice [current account]"

We wonder about the reporting of overnight accounts and advances and on the scope of templates 5 and 7: - overnight accounts and advances with counterparties "central banks and credit institutions" are not reported on a "loans and advances" row in table 1.1 but on the rows 030 et 040 ; nevertheless, do they have to be reported in tables 5 and 7 which concern "loans and advances" ? If yes, do they have to be reported on the row "On demand [call] and short notice [current account]"? - does overnight accounts and advances with other counterparties have to be reported on the row "On demand [call] and short notice [current account]" in tables 5 and 7 ?

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_235| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 11/09/2013

Annex XV Validation formulae, "≡" vs "="

We would like to know what the differences are, for the validation formulae purpose, between the symbols "≡" and "=". E.g: Validation {F 20.04 , r140 , c030}≡{F 20.07 , r190 , c020} (without ID). Does this validation mean that the value of both "boxes" o "line items" is the same or, on the contrary, that the "concept" they both refer to is the same? We though it was the first option until we bumped into this question. If it were the second alternative, should it appear in the majority of validation links?

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_231| Topic: Supervisory reporting - Other| Date of submission: 10/09/2013

FINREP F45.2

Row 010 "Property, plan and equipment" has been eliminated. Notwithstanding, currently the first row (Investment property) is row 020, not row 010. Hence, should the row 040 "Other assets" include the information previously contained in row 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_219| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 09/09/2013

Annex III F20.4 row 210 Of which: Commercial immovable property

What is the information requested in this row? Does it consist of loans collateralized by commercial immovable property, similarly to row 230? Or is it made up of loans granted to acquire commercial 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_216| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 09/09/2013