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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

List of Q&A's

Recognition of non-transferable liquidity held by and arising in third country subsidiaries in the context of the calculation of the consolidated LCR

What is the (combined) treatment of liquid assets held by and liquidity inflows arising in third country subsidiaries being subject to transfer restrictions for the purpose of the calculation of the LCR at consolidated level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

Table F12.01 – Movements in allowance and provisions for credit losses

Considering the greyed out columns in row 350 and 550: How can the actual movement of impairment be reflected correctly?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Prudential treatment of goodwill and other intangible assets arising from the acquisition of an asset manager by an insurance undertaking fully owned by a bank

For the purposes of a deduction under Articles 36(1)(b) and 37 of the CRR, should a bank, which owns 100% of an insurance undertaking which acquires a controlling shareholding in an asset manager, deduct goodwill and other intangible assets (Article 4(1)(113) and (115) of the CRR) generated by the acquisition carried out by its insurance undertaking subsidiary?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

breakdown of total exposures by risk weights

How should exposures subject to a risk weight of 70% according to Art. 126 (2) CRR3 be reported in the ITS on supervisory reporting v4.0? Should these exposures be included in the row r0280 “other risk weights” of the template C 07.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Presentation of fully matured loans and deposits in templates F05.01 and F08.01

Could you please clarify how fully matured loans and deposits should be presented in templates F05.01 and F08.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Treatment of Net Interest Income Stress Outlier Test (NII SOT) in scenarios where breaches occur due to one-off effects (EBA/RTS/2022/10)

Could you please provide guidance on how banks should approach the reporting of such NII SOT breaches arising from such short-term, non-structural events and in addition how is it foreseen that the regulator should govern such cases? Specifically, are there any provisions or considerations that can be applied to account for these temporary effects without misrepresenting the bank's overall NII sensitivity? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 530/2014 - RTS on materiality of thresholds for internal approaches to specific risk in the trading book

Template EU MR4 missing from Annex

The EBA Pillar 3 mapping tool mentions template EU MR4. I cannot find this in any of the annexes. Is this template relevant?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Definition of ‘subordinated liabilities’ for FINREP reporting

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Scaling of gross JTD amounts of securitisation tranches with a maturity less than one year

Should the tranche maturity (MT) of less than one year of gross JTD amounts of securitisation tranches resulting from either formula in Art. 257(1) CRR be floored at one year as required by para. 2 of this Article, or can the MT be used without this floor of one year in order to enable scaling, with a floor of three months, as prescribed by Art. 325z(5) CRR in conjunction with Art. 325x(3) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of Delta GIRR risk-free interest rate curves

Which risk-free interest rate curves per currency should be considered as different curves? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Sign convention on EVE, NII and MV levels in Template J_01.00 and J_02.00

If the value of EVE,  NII and MV level in columns c0030, c0100, c0130 of template J_02.00 result in a negative sign, is it correct to input a positive sign in template J_01.00 for the same items as requested by the validation rules?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Exemption from approval for financial holding companies or mixed financial holding companies as per Directive 2013/36/EU (CRD) Article 21a (4) (d)

Should the criterion in Article 21a (4) (d) CRD (engagement in taking management, operational or financial decisions affecting the group or its subsidiaries) be considered to be met if the some persons are represented on the governing bodies of both the (mixed) financial holding company and an institution that is a subsidiary?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Reported amount in F09.02 col0010 if overcollateralization can occur

How should financial guarantees be reported in F09.02 if the value of the guarantee exceeds the loan exposure (possible overcollateralization)?Example:There is a credit risk mitigation group including 2 financial guarantees and 1 loan exposure as follows:Financial guarantee nr.1 - 15 000 EURFinancial guarantee nr.2 - 17 000 EURLoan exposure - 14 000 EURReported amount in F09.02 col0010 = ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Date of Disclosure

CRR Art. 433 states that the disclosure should happen the date of the publication of the financial statements. Due to the imlempentation of CRR III EBA granted an extention to submit Q1 regulatory reports to the 30.06. How should the disclosure be handled?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Validation rules taxonomy V4.0 C08.01 v4770_m

The formula v4770_m specifies that for C08.01, the total sheet is the sum of all the IRB Foundation sheets, including the memorandum items.However, Final ITS instructions specify that memo subcategories must be reported separately as a subclass of exposure, not linked to the total IRB exposures classes. Also, in the C02.00, lines with reference to memorandum items are shaded and not included in the totalization.The control seems incoherent.Could you please therefore confirm that sheets with reference to memo items should be removed from the formula?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules taxonomy V4.0 C08.01 v4769_m

The formula v4769_m specifies that for C08.01, the total sheet is the sum of all the IRB Advanced sheets, including the memorandum items.However, Final ITS instructions specify that memo subcategories must be reported separately as a subclass of exposure, not linked to the total IRB exposures classes. Also, in the C02.00, lines with reference to memorandum items are shaded and not included in the totalization.The control seems incoherent.Could you please therefore confirm that sheets  with reference to memo items should not be taken into account in the formula?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules taxonomy V4.0 C09.02 v6052_m

According to the formulae v6052_m : {r0150} = {r0010} + {r0011} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0125, c0130 in C09.02 “CR GB 2”.This control ensures that the sum of exposures declared in line 0150 "Total exposures" is equal to the sum of lines 0010 "Central governments or central banks", 0011 "Of which: Regional governments or local authorities", 0012 "Regional governments or local authorities", 0013 "Public sector entities", 0020 "Institutions", 0030 "Corporates", 0060 "Retail", 0132 "Collective investments undertakings (CIU)" and 00140 "Equity" in CR GB 2.However, the line 0011 is an "of which" of the line 0010 which is also in the formula, this means that it will be doubly taken into account in the totalization.Could you please therefore confirm that the line 0011 should be deleted from the formula?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules taxonomy V4.0 C09.02 v23650_h

According to the formulae v23650_h : {r0030} = {r0050} + {r0051} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0121, c0122, c0125, c0130 in C09.02 “CR GB 2”.This control makes the comparative between r0030 “Corporates” and the sum of lines r0050 “Of Which: SME” and r0051 “Of Which: Large Corporates" in CR GB 2.However, in Annex 2, the instructions for line 0030 refer to Article 147(2), point (c), of Regulation (EU) No 575/2013 which classifies Corporates as the following : i)General Corporate, ii) Specialized financing exposures and iii)Purchased receivables. The control seems incoherent since lines r0050 and r0051 expect "of which" items.To be compliant with the corporate categories defined in Article 147, line 0030 should be compared with the totalization of lines 0052 "Specialized lending", 0057 "Purchased receivables" and 0058 "Others".Could you please therefore confirm that the control needs to be modified?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Classification as a “specialised debt restructurer” (SDR) pursuant to Article 36(5) of Regulation No 575/2013

To be classified as specialised debt restructurer in accordance with Article 36(5) of the Regulation No 575/2013 (CRR), an institution’s sight deposits must not exceed 5% of its total liabilities. How should the term “sight deposits” be interpreted in the context of the Article 36(5) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Classification as a “specialised debt restructurer” (SDR) pursuant to Article 36(5) of Regulation No 575/2013

For how long prior to an institution’s classification as a specialised debt restructurer must all criteria specified in Article 36(5) of Regulation No 575/2013 be met by the institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable