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Conditions for the filling of template C 33.00

If a bank will move to IFRS9 accounting standards starting from 1 July 2018, the first date for the Corep reporting under IFRS9 will be 30 September 2018. Therefore, at 30 June 2018 the new logic of the IFRS9 accounting portfolios is not available in data systems and it would be difficult to complete the new model C 33.00. We would like to know if the bank still need to fill in the template C 33.00 at 30 June 2018 and, if so, what logic it has to use.

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

ID: 2018_4072| Topic: Supervisory reporting| Date of submission: 03/07/2018

Double counting of intra-group funding in C68.00

"In C68.00 Unsecured wholesale funding (row 110) should be split per product type: - of which loans and deposits from financial customers (row 120) - of which loans and deposits from non-financial customers (row 130) - of which loans and deposits from intra-group entities (row 140) Should intragroup funding be reported exclusively in row 140? Or should it be reported in row 140 AND in row 120/130 depending if the intragroup entity is a financial or a non-financial customer? The same question applies to the split of wholesale funding."

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

ID: 2018_3962| Topic: Supervisory reporting| Date of submission: 07/06/2018

Incorrect validation rule v4456_m

The validation rule v4456_m is not correctly defined in the taxonomy 2.7. Prerequisites are following: C 47.00 and C 43.00.a and C 43.00.b and C 43.00.c It means that all tables have to be reported. However a bank with a standardised approach to credit risk do not report table C 43.00.c. Consequently the rule can not be applied. In theory a bank can have no data for the table C 43.00.a as well.

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

ID: 2018_3950| Topic: Supervisory reporting| Date of submission: 01/06/2018

Is the scope of the RTS on strong customer authentication (SCA) and secure communication one-leg or two-leg?

Does the PSD2 requirement on SCA, and subsequently the detailed requirements in the RTS on SCA including the practical usage of the allowed exemptions, apply also to one-leg transactions, with regards to:Transactions with the payer’s payment service providers (PSP) outside the EEA (credit transfers as well as card-based payments)?Credit transfers with the payer’s PSP inside the EEA and the payee’s PSP outside the EEA?Card-based payments with the payer’s PSP (the issuer) inside the EEA and the payee’s PSP (the acquirer) outside the EEA, when the non-EEA acquirer do support SCA?Card-based payments with the payer’s PSP (the issuer) inside the EEA and the payee’s PSP (the acquirer) outside the EEA, when the non-EEA acquirer does not support SCA?

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

ID: 2018_4233| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 06/09/2018

The Implementation of the electronic communications exclusion in the voiced-based premium rate services market

Considering the organisation of the voiced-based premium rate services market, and considering the interpretations proposed for the electronic communications exclusion (ECE) in the different countries, as far as a payment transaction complies with the conditions imposed by the ECE, does the ECE apply to the whole value chain, and therefore, all the providers of electronic communications networks or services involved in payment transactions covered by the ECE should not have to register as payment institutions or agents for these operations?

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

ID: 2018_4181| Topic: Other topics| Date of submission: 06/08/2018

Geographical scope of application of the RTS on strong customer authentication (SCA) and secure communication requirements – ‘Two-leg’ transactions

Is it necessary that issuer, acquirer, cardholder and merchant be all located in the EEA for the RTS on SCA requirements to apply to two-leg transactions?May the issuer use the merchant’s location as a proxy (in lieu of the acquirer’s location)?

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

ID: 2018_4030| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

IFRS 9 Transitional Arrangements - Business Combination

There is a business combination between banks which decided to apply the static and dynamic phase in the arrangements envisaged by Article 473a CRR. 1) How should the static phase-in arrangements envisaged by Article 473a CRR apply on the consolidated basis? 2) How should the dynamic phase-in arrangements envisaged by Article 473a CRR apply on the consolidated basis?

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

ID: 2018_4391| Topic: Accounting and auditing| Date of submission: 25/11/2018

What is considered as a dedicated interface

Payment Service Users (PSUs) communicate with an account servicing payment service provider (ASPSP) via Web using HTTP while mobile PSUs and Third Party Providers (TPPs) via REST Application Programming Interfaces (APIs) but in all cases the processing is done by the same back-end server using the same credentials, authorisations and business logic. In the case of mobile and TPP channels, the APIs are similar and are exposed from the same ASPSP’s gateway. Any issue in the back-end server will result in downtime for all channels. Clarification is required whether this solution is considered as a dedicated interface or not.

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

ID: 2019_4681| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 25/04/2019

Inclusion of time taken for SCA in the performance KPI

Does the Key Performance Indicator (KPI) for the performance of the dedicated interface include the time taken for conducting Strong Customer Authentication (SCA)? 

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

ID: 2019_4661| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 08/04/2019

Contactless transactions - SCA

Does the cumulative count / authorised sum amount apply to any contactless authorisation request, regardless if the request was approved or not?

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

ID: 2018_4230| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 05/09/2018

SCA at vending machines without PIN pad

Do transactions at vending machines without PIN pad require Strong Customer Authentication (SCA)?

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

ID: 2018_4057| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Review of security measures

When an issuer delegates strong customer authentication (SCA) to a third-party (e.g. a smartphone manufacturer), what are the requirements for such delegation? Should the issuer conduct an evaluation of the technical features and security of third-party’s devices and solutions?

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

ID: 2018_4047| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Treatment of failed SRT under Traditional Securitisation

In case the significant credit risk cannot be considered to have been transferred according to Article 243, but the exposures had been already derecognised from the bank's balance sheet, shall the bank continue to calculate the RWA for the securitised exposures as if they were never securitised? Does it mean that no RWA will be calculated for the securitisation position?   Additionally, if the exposures have been securitised against cash, and the cash invested in new loan, would RWA be calculated for these new loans

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

ID: 2018_4207| Topic: Credit risk| Date of submission: 20/08/2018

Timely payment requirement for unfunded credit protection provided under credit risk insurance policies

Does unfunded credit protection - which a bank has purchased in order to hedge a loan exposure and which provides the protection-seller with the contractual right to compensate credit losses according to the original scheduled payment dates of the hedged loan - fulfil the timely payment requirement for unfunded credit protection in a situation where the loan becomes due and payable prior to the original scheduled payment dates?

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

ID: 2017_3576| Topic: Credit risk| Date of submission: 27/10/2017

Proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU as off-balance sheet exposures

Are the binding proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU off-balance sheet exposures according to Annex I CRR? Should FINREP,COREP reporting include such binding proposals for mortgage credit extension?

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

ID: 2017_3376| Topic: Credit risk| Date of submission: 03/07/2017

Clarification of negative RWA--, Annex III, Benchmarking exercise

What should we do if the value of RWA-- gets negative? Should we do nothing or should the value change to example 0?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting for Institutions (for benchmarking the internal approaches)

ID: 2019_4459| Topic: Supervisory reporting| Date of submission: 14/01/2019

EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)

What is the correct interpretation of instrument No.40?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)

ID: 2018_4428| Topic: Supervisory reporting| Date of submission: 20/12/2018

Definition of numerator for loss rate

How should the numerator of the loss rate be computed when some credit adjustments are applied to the exposure before the default date.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting for Institutions (for benchmarking the internal approaches)

ID: 2018_4293| Topic: Supervisory reporting| Date of submission: 25/09/2018

Definition of PD*/PD** for RWA*/RWA**

Regarding the treatment of continuous ratings, the former description of RWA*/** stated: "An institution using continuous PD shall first determine the PD* for the average PD of each obligor grade and subsequently apply by obligor grade the same relative deviation between PD and PD* at counterpart level as for the average PD and PD* at obligor grade level." This paragraph has been deleted for RWA-/--/+/++. Shall the rating grade used for reporting requirements by the bank be used for the caclulation of p-/--/+/++?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting for Institutions (for benchmarking the internal approaches)

ID: 2018_4292| Topic: Supervisory reporting| Date of submission: 25/09/2018

Definition of RWA* and RWA**

The application portfolios of RWA-/--/+/++ are defined as follows in Annex IV: CORP_ALL_0086_**_****_**_Rx0, SMEC_ALL_0106_**_****_**_Rx0, SMEC_ALL_0106_**_****_**_Rx0, MORT_ALL_0094_**_****_**_Rx0. However, in Annex I these portfolios exist with a suffix ALL, ONX, OFF und OTH only. Shall RWA-/--/+/++ be reported for all these portfolios?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting for Institutions (for benchmarking the internal approaches)

ID: 2018_4291| Topic: Supervisory reporting| Date of submission: 25/09/2018

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