List of Q&As

Financial guarantees received and other commitments received (F 09.02)

1) Could you confirm that the item "Financial guarantees received" (see F 09.02, r080 – r140, c010) includes only financial guarantees received as collateral for the institution's liabilities and for institution's financial guarantees given or other commitments given (i.e. it does not include financial guarantees received as collateral for claims/financial assets, given the fact that they are considered as part of information in template F 13.01 Breakdown of loans and advances by collateral and guarantees)? 2) Consequentially we would like to clarify the treatment of other collateral received (either from the customer or from third party) for financial guarantees given and other commitments given (from template F 09.01). Should they be also included in item "Other Commitments received" of template F 09.02 (r150 – r210, c020)?

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_214| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 05/09/2013

Specifying default fund contribution or risk weights in C07.00 and connection to C02.00.

First, according to column 020, default fund contributions is included in column 010 (original exposure) since it is a "of which". To get row 090 - 210 to sum up to the total exposure at row 010, the default fund contribution must then also be specified on row 090-210. Since the default fund contribution not is calculated with those fixed risk weights, on which row should the amount then be inserted? Secondly, should the amount in C07.00, c220, r010 be splitted on C02.00, row 460 and 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_209| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 03/09/2013

FINREP: F07.00 reporting of past due assets

How to split past due not impaired financial assets according to the number of days past due? According to the Instructions in Part 2, paragraph 48: “Assets qualify as past due when a counterparty has failed to make a payment when contractually due”. Q1: Will the whole asset/loan be qualified as past due or only its part, for which the counterparty failed to make a payment? According to the Instructions in Part 2, paragraph 48 : “The amounts of such assets shall be reported and broken down according to the number of days past due”. Q2: Should the individual financial asset/loan be split into parts according to the “age” of individual instalments or should the financial asset/loan be reported in the col. for the “oldest” past due instalment? In this case “to split” will be relevant to financial assets portfolio (= individual asset will be kept as a whole, but portfolio will be split) .

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_194| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 29/08/2013

Leverage Ratio: C45.00 (LRCalc) r010: SFTs exposure according to CRR 220

The exposure for repurchase transactions, securities or commodities lending or borrowing transactions, long settlement transactions and margin lending transactions should be calculated in accordance with Article 220 (1) to (3). Should the volatility adjustments be taken into account for the determination of the leverage ratio exposure value of exposures subject to Article 220?

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_188| Topic: Supervisory reporting - Leverage ratio| Date of submission: 28/08/2013

FINREP: Counterparty breakdown - hospitals, schools, social secretaries

As what counterparty shall hospitals, schools and social secretaries be reported? Are there any thresholds (e.g. turnover) which when exceeded then the entity shall be reported as different counterparty (e.g. in current FINREP hospitals are treated households, when turnover exceed the limit then the hospital is reported as corporate)?

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_184| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 26/08/2013

NSFR: Calculation of liablities and receivables from derivatives if there is no netting agreement

NSFR: How should the amount of liablities and receivables from derivatives be calculated if there is no netting agreement with the counterparty?

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_183| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 26/08/2013

FINREP: F1.1. row 040 "other demand deposits"

On the basis of the validation rules of template F1.1, row 040 is part of the sum of row 010 'cash and cash balances at central banks'. So one can assume that row 040 'other demand deposits' are deposits with central banks. However, the guidance in annex V part 2.3 (1.1 assets - § 3) stipulates that 'other demand deposits' includes balances receivable on demand with credit institutions. This seems contradictory to us. Please can you confirm whether row 040 of template F1.1, comprises 'other demand deposits' with central banks or with credit 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: 2013_180| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 23/08/2013

FINREP: Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net

During the last update on the ITS Annex III in July 2013 the FINREP P&L template was modified by removing the line item for "Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net" (table 2 row 320 ITSoR March 2013) without any explanation. But in comparison with the published DPM in July 2013 which still contains the line item there is an inconsistency. In our opinion the line item is required to reach a consistent and meaningful P&L Statement, so that we assume that removing the line item is a mistake in the templates. If it is not an error it is necessary to give guidance on the disclosure of gains or losses on derecognition of investments in subsidiaries, joint ventures and associates.

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_178| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 22/08/2013

COREP C25.00 (CVA): rows 030 and 040 for column 110 shouldn't be reported

in CVA report, the column 110 is requested for all methods but when we check the definition of this column "number of counterparties where the credit spread was determined using a proxy instead of directly observed market data". This definition suits more for CVA advanced method but no for standard method nor for based OEM, our question is the proxy used to determine credit spread is it really requested for standard method or OEM?

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_171| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 19/08/2013

FINREP validation rules - references to missing rows

In the Validation Formulae (Appendix XV), there are many rows referred to that do not exist in the template (Appendix III). For example, in table 1.1 it is referred to rows 091, 092, 093, 094, 095, 171, 172, 173, 174, 175, 176, 177, 178, 231, 232, 233, 234, 235, 236 and 237, which do not exist in the template. There are many other similar examples. How should we interpret/handle these validation rules?

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_165| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 16/08/2013

FINREP Template F 06.00 - reporting by country

Template 6 - Breakdown of loans and advances to non-financial corporations by NACE codes and by residence of the counterparty. Should this table be delivered per country?

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_161| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 14/08/2013

FINREP: Calculation of accumulated changes in fair values- first application

Is it possible to apply a starting date for calculation of accumulated changes in fair values?

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_158| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 14/08/2013

FINREP - Company only IFRS reporting

Please confirm the reporting requirements for a broker dealer reporting stand-alone company accounts under IFRS. Current reading of the guidance suggests that such an entity would be out of scope.

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_153| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 12/08/2013

Validation Rules - Mistakes in the Annex XV

- In the validation rules file, a confusion is made between rows and columns in excel columns 'H' and 'I'. - The validation rule for row item 330 of the FINREP template F 01.01 is missing

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_152| Topic: Supervisory reporting - Other| Date of submission: 12/08/2013

Liquidity: Instructions on reporting outflows in relation to custody, clearing and cash managment

Are the references to the Basel rules correct? Looking at the January 2013 Basel document, paragrapphs 75 and 76 referred to in the instructions do not appear to be the relevant in this context, as they refer to stable retail deposits.

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_150| Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)| Date of submission: 09/08/2013

FINREP Reporting for firms with Accounting Reference Date other than 31 December

Article 18 (3) confirms that FINREP applies from 1 July 2014. We have a financial year end of 30 September which means that where we will report our first quarter's data for relevant templates (in full) as at 30 September 2014. For semi-annual templates should we only report a quarter's data in our first submission (1 July to end September) or should we start collecting data from 1 October, and report a full 6 months of data as at 31 March 2015? For annual templates should we only report a quarter's data in our first submission (1 July to end September) or should we start collecting data from 1 October, and report a full year's data as at 31 March 2015? The period 1 July 2014 to 30 September 2014 is a full quarter, so this will allow us to report a full quarter's 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_147| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 09/08/2013

COREP CA1: Reference to CRR Art 3 is unclear

CA1 Row 524 Column 010 relates to Article 3 of CRR. Article 3 of CRR, relating to Application of stricter requirements by institutions states: "This Regulation shall not prevent institutions from holding own funds and their components in excess of, or applying measures that are stricter than those required by this Regulation. Can the EBA please confirm if this relates to the difference between Capital Requirement and Capital Holdings? Alternatively is this cell intended to reflect any additional capital holding dictated by competent authorities?

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_146| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 09/08/2013

Leverage ratio: Exposure value of derivatives

Article 429.6 of Regulation (EU) No 575/2013 (CRR) states that the exposure value of financial derivatives listed in Annex II and of credit derivatives shall be calculated in accordance with the Mark-to-Market method (see Art. 274 of CRR). Based on such instructions, it is not clear if the above mentioned method shall be applied both to OTC and exchange trade derivatives, also including those contracts cleared with CCPs.

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_145| Topic: Supervisory reporting - Leverage ratio| Date of submission: 09/08/2013

COREP: 'residence of the obligor' for the purposes of the CRGB1 template for supranational organisations and multilateral development banks

The guidelines for the CR GB 1 COREP template, Geographical breakdown of exposures by residence of the obligor, state that 'residence of the obligor' refers to the country of incorporation. However, how is this guideline to be applied in the case of exposures to either supranational organisations such as the EU (European Union) or multilateral development banks such as the EIB (European Investment Bank)?

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_143| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 08/08/2013

Remittance dates in case of an accounting year-end which deviates from the calendar year

Is our understanding that submission of "financial information" based on their accounting year-end which deviates from the calendar year is relevant to FINREP templates only, but not to wider financial and prudential information (incl. COREP, LE, LR, LCR...) as well, 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_142| Topic: Supervisory reporting - Other| Date of submission: 08/08/2013