Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Classification of invoice discount facilities as full risk items

1. Should invoice discount facilities always be classified as full risk items or may such facilities be classified as medium/low or low risk if they may be cancelled with immediate effect when the assumptions used for setting the limit change? 2. Should the nominal value of an invoice discount facility as an off-balance sheet item be calculated as the difference between the contractual limits of the total credit volumes of clients and the amounts that have been paid to clients for the discounted invoices not yet due for payment from customers?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1324
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/10/2014

Conditons to be fulfilled when netting positions in market risk of third countries

According to Article 325 (3) letter b CRR undertakings located in third countries have to comply, on an individual basis, with own funds requirements "equivalent to those laid down in this Regulation". To assess whether this condition is fulfilled by the third country institution, is it sufficient for the institution to look only on Article 92 CRR, or has the assessment to be based on e.g. Article 25, 51 et seq., 63 et seq, 102 and 325 CRR or even on the CRR as a whole? In particular, is there a relation to the Commission´s delegated act on third country equivalence that will be issued by the end of 2014? Once the delegated act on third country equivalence is issued, will supervisors and institutions be able to treat exposures to the third countries mentioned therein as equivalent without effecting further analyses under Article 325 (3) letter b CRR? With regard to Article 325 (3) letter c CRR: what proof of evidence is deemed necessary to assess the fulfillment of this condition? Is this Article fulfilled if a lawyer located in the respective third country states that there is no regulation in place which might significantly affect the transfer of funds within the group? Does this opinion have to be given e.g. by a lawyer resident in the home country of the third country institution or the country of the institution wanting to apply Article 325 CRR or the third country regulator? As we are of the opinion that letter c is hard to be fulfilled (or rather evidence is hard to provide) we would like to understand the rationale behind this condition.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1323
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Calculation of the remuneration bracket

Could EBA clarify which categories of staff should be taken into account when the remuneration bracket is calculated?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 604/2014 - RTS Remuneration: criteria to identify categories of staff
  • ID: 2014_1321
  • Topic: Remuneration
  • Date of submission:

Reporting of positions in closely correlated currencies (CRR Art. 354)

Template C 22..00 (MARKET RISK: STANDARDISED APPROACHES FOR FOREIGN EXCHANGE RISK (MKR SA FX) wrongly assumes that any pair of currencies closely correlated (row 020) can only be two non-reporting currencies. In fact, one of them can be the reporting currency of the reporting institution. This requires change of the title of the aggregate row 010 as well of the common title of columns 060-080.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1318
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Definition of "Other collateralized loans" in relation to validation rules between F 05.00 (r100) and F 13.01 (c030, c040)

Do credit institutions in row "of which: other collateralized loans" in the tables F 05.00 and F 07.00 include also loans and advances that are secured by received financial guarantees or other guarantees? Final draft ITS on supervisory requirements in Annex V, Part 2.41 (i) for Tables F 5.00 states: “Other collateralized loans” include loans formally backed by collateral, independently of their loan/collateral ratio (so-called “loan-to-value”), other than “Loans collateralised by immovable property”, “Finance leases” and “Reverse repurchase loans”. This collateral includes pledges of securities, cash, and other collateral."

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1309
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

AE-COL (F 32.02), AE-MAT (F 33.00).

1) Meldebogen AE-COL: Nach unserer Auffassung sind nur solche Sicherheiten relevant, die im Groß- und Interbankenhandel Anwendung finden. Sicherheiten in Privatkundendepots werden dabei unberücksichtigt. Ist diese Annahme richtig? Beispiel: Die Bank gewährt dem Kunden einen Wertpapierkredit, damit er Wertpapiere erwirbt. Der Kunde verpfändet diese Wertpapiere dann als Sicherheit. Sind diese als erhaltene Sicherheiten zu berücksichtigen? 2) Meldebogen AE-MAT: Die gestellten Sicherheiten müssen mit den Restlaufzeiten der zugrunde liegenden Transaktionen gemeldet werden. Auf der Passivseite sind für unser Institut hunderte von Geschäften relevant. Soll dabei die Restlaufzeit jeder einzelnen Transaktion berücksichtigt werden oder ist eine Durchschnittsrechnung der Laufzeit bzw. pauschale Anrechnung im letzten Laufzeitband ausreichend? Beispiel: Die Bank refinanziert sich über Refi-Darlehen. Hunderten von Darlehen steht ein Wertpapier als Sicherheit gegenüber. Soll der Wert des Papiers proportional auf die Restlaufzeiten der einzelnen Darlehen aufgeteilt werden oder ist eine Ermittlung der Durchschnittslaufzeit ausreichend?1) AE-COL template (F 32.02): in our view, only collateral used in wholesale and interbank trading is relevant. Collateral in private customer portfolios is thereby not takeninto consideration. Is this assumption correct?For example, the bank grants the customer a loan against securities so that he can acquire securities. The customer then pledges those securities as collateral. Are they tobe taken into consideration as collateral received?2) AE-MAT template (F 33.00): the collateral posted must be reported with the residual maturities of the underlying transactions. On the liabilities side, hundreds of transactionsare relevant for our institution. Should the residual maturity of each individual transaction be taken into consideration or is an average maturity calculation or an overall imputationin the final maturity band sufficient?For example, the bank refinances its operations using refinancing loans. Hundreds of loans are covered by one security as collateral. Should the value of the security becredited pro rata to the residual maturities of the individual loans or is it sufficient to determine the average maturity?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1306
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/06/2021

Difference between and Annex I/ Annex II/1.6 description and DPM descrption of the same table name

There is a difference regarding the name of table C 05.02 Capital Adequacy, between Annex I sheet C 05.02/ Annex II Own funds paragraph 1.6 and DPM Database/ DPM Table Layout. While in Annex I/II name is 'Grandfathered instruments: Instruments NOT constituting State aid (CA5.2)' in DPM Database/DPM table layout, namie is 'C 05.02 - Capital Adequacy - Transitional provisions: Grandfathered instruments constituting State aid'. Please confirm what name is correct and should be used for table C 05.02 Capital Adequacy related to Grandfathered instruments (with NOT or without 'not').

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1305
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Material exposure in connection with term "days past-due" in the definition of non-performing exposure

What is the reading of the term "material" exposure in connection with "days past-due" for the purpose of definition of non-performing exposure?Can the "materiality threshold" be applied in a way that the counting of days past due starts when the past-due amount of the whole exposure of the obligor exceeds pre-defined materiality threshold?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1297
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Memorandum Items in Credit Risk SA

Can you please confirm that the memorandum items in row 290-320 only should 1. Include Exposures secured by immovable property under articles 124,125 and 126 2. In case of the exposure being to a "High Risk" customer that is fully secured by an eg. RRE then the in template C 07.00 - exposure class "High Risk" no memorandum items will be completed (based on point 54 of the instruction as High Risk Category is not one of them) BUT instead the original asset class of the high risk obligor eg. Corporate should be completed

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1295
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Reporting of significant currencies (> 5%) according to Art. 415 (2) lit. a CRR

XBRL taxonomy requires the "total” of all currencies plus a breakdown for each "significant currency". This lead us to the following questions: 1) What is the definition of “total”? 2) Has the reporting currency itself (which will be in any case greater than 5%) to be reported separately as “significant currency”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1294
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 08/04/2016

Classification of institution in LR5

What should be reported in {LR5;040;1} in case of brokerage houses?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1287
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Supplementary Reporting

In templates C51.00 to C53.00, which criteria should be applied to determine the items subject to Supplementary Reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1272
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 24/01/2022

Incorrect legal references

Which are the correct legal references of the item in row 020 of template Grandfathered Instruments: Instruments not Constituing State Aid (C05.02)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1269
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Derivatives not shown in the Balance Sheet and Derivates shown as Liabilities

Are derivatives shown as assets on the balance sheet or derivatives shown in CoRep basis for template LR1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1267
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Use of an insitution's own estimates of conversion factors

In applying Article 166(10) of Regulation (EU) No 575/2013 (CRR), may competent authorities grant permission to institutions to use their own estimates of conversion factors (as is permitted for certain exposures under Articles 151(7) and (9)) for off-balance sheet exposures which are not listed under Article 166(8)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1263
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/11/2014

Annex I, C 05.01

I am a little confused by two validations with the ID of V2000_s and V2035_s. My understanding is that column 50 should be a percentage but validation rule (V2035_s) states that it must be >=0 and column 10 should be the absolute number but the validation rule (V2000_s) shows that this should be <=0.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1261
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Shareholder approval for a firm to increase the permitted ratio of fixed to variable remuneration

(i) Could the EBA clarify the procedure to be followed for a firm to increase the variable remuneration above the basic limit of 100 % of the fixed remuneration. In particular with regard to: whether the percentages referred to in the second indent of 94(1)(g)(ii) should be counted by reference to share or ownership voting rights or the number of individual shareholders or owners, (ii) whether the 75% threshold, which applies when fewer than 50% of shares are represented in the vote and the 66% threshold, which applies when at least 50% of shares are represented, are percentages of the share or ownership voting rights represented or the firm’s whole issued share capital or ownership rights, (iii) is there a definition of the concept of shares or ownership rights being “represented”? (iv) Can staff who are directly concerned by the higher maximum levels of variable remuneration exercise any voting rights they may have?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1260
  • Topic: Remuneration
  • Date of submission:

Reporting ICAAP requirements

Where does a firm report its ICAAP requirement if it has not undergone a SREP or been notified by its National Competent Authority that it must take additional own funds requirements

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2014_1258
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Report information on the 20 largest exposures to clients or groups of connected clients

An institution has to report information on its large exposure, on its 10 largest exposures to institutions as well as on the 10 largest exposures to unregulated financial entities according to Article 394 . Furthermore, an IRBA institution also has to report its 20 largest exposures sorted by the non exempted exposure value (resulting from subtracting the amount in column 320 ‘Amounts exempted’ of template LE2 from the amount in column 210 ‘Total’ of that same template, according to annex IX). In case the institution has already reported some of these 20 counterparts as large exposure or in one of the two TOP 10, does this institution: -have not report those who are already reported in the same template ? -have to complete the template with the next ones in order to report a total of 20 largest exposures ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1256
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Determining the exposure value for regular way securities transactions

If settlement date accounting is employed in the recording of regular way securities transactions then there are no balance sheet entries between trade date and settlement date. In this case would the impact of unsettled transactions not be included in the exposure value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1255
  • Topic: Leverage ratio
  • Date of submission: