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List of Q&A's

In template C 34.02, the field "Exposures" aims to report separately all CCR exposures and all CCR exposures excluding exposures to central counterparties (CCPs). In the DPM taxonomy 3.0 and the related annotated template, this exclusion seems to refer to QCCPs only.

Shall we exclude all exposures to CCPs from Template C 34.02 or only exposures to QCCPs ? The annotated template C 34.02(0002) is currently referring to the "Counterparty" member value (CT:x81) Non-QCCPs, which makes no sense with the exclusion required in Annex II.

  • 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
  • ID: 2020_5674
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/11/2021

Legal requirements for the authentication procedure when SCA exemptions are applied for remote payment transactions

What are the legal requirements for the type of authentication procedure used when conditions for the application of of Strong customer authentication (SCA) exemption for remote payment transactions are fulfilled?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2020_5673
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/04/2021

Prudential consolidation of special funds

Strictly following the instructions for presenting fully owned CIUs in FINREP leads to possibly unwanted outcomes as compared to IFRS accounts. Can competent authorities allow for fully owned CIUs to be consolidated in order to allow for the use of a look-through approach for FINREP?

  • 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
  • ID: 2020_5668
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 26/11/2021

Definition of “prudential regulation in the Union” in Article 142(1)(4)(b)

Can insurance and re-insurance undertakings located in the EU be considered as non-prudentially regulated and therefore as non-eligible to the definition of large financial sector entity?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5666
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Simultaneous applicability of non-deduction exemptions under Articles 48 and 49 CRR regarding equity exposures on insurance holdings where an institution has a significant investment

For an institution that has received permission to apply Article 49(1) CRR, has a significant investment below or equal to the threshold indicated in Article 48(1) and 48(2) (exempted from being deducted from Common Equity Tier 1 according to Article 49(1), are the amounts of holdings in insurance undertakings, to be risk-weighted at 250% according to Article 48(4) and the amounts of such holdings that are above this threshold risk-weighted in line with Article 49(4)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5664
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Reporting of the Securitisation of liabilities in C_14 report (SEC DETAILS) when the ultimate underlying is originally issued by another entity than the reporting institution.

When financial liabilities are the ultimate underlying of a given securitisation and when those liabilities have originally been issued by another institution than the reporting one, how should the column c160 (type of underlying assets) be reported ?

  • 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: 2020_5661
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Consent solicitation to change the contractual ranking of an instrument to avoid so-called “infection risk“ posed by legacy instruments

Would a consent solicitation to amend the T&Cs of a legacy capital instrument (Tier 1 or Tier 2) in order to ‘promote’ an instrument in the subordination hierarchy entail the instrument to be deemed as a new issuance?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5653
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 22/02/2022

Requirements towards SCA if association is done based on phone call

Does the requirement to apply Strong customer authentication (SCA) under Article 24 paragraph 2 b of Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication apply when customer is served using telephone call? Or is the only possibility to associate authentication credentials with the customer not having active credentials at hand, only possible having customer present?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2020_5650
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Follow-up question on 2019_4818 related to CB Eligible Central bank withdrawable reserve to be reported in memo line 13 C 66.

As clarified in 2019_4818 that withdrawable central bank reserve may be reported as CB eligible in C71. The same CB reserve is reported in C66 row 3.2 also as CB eligible. In C66 CB eligible HQLA are reported in memo line 13. C66 instruction has specifically mentioned to report row 3.3, 3.4 and 3.5 CB eligible values in memo line 13. As we have now agreed to report CB withdrawable reserve as CB eligible for C71 should this also be included in memo line 13 of C66 reporting.

  • 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: 2020_5646
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Definition of the parameter ρ_kl (option maturity)

How is the parameter “ρ_kl (option maturity)” concretely determined? Does the calculation take place at the level of a single option or at the level of weighted net sensitivity, which may consist of several options?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5645
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Guarantee for the purpose of the waiver from internal MREL requirements

What amount of the “commitments” referred to in Articles 45f(3) and 45f(4), point (d), BRRD should be covered by the guarantee of the resolution entity or the parent undertaking?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5644
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 29/07/2022

Delegation of 2-Factor Authentication (2FA) to PISP, AISP or other third party

Where a Payment Service Provider (PSP) is providing financial services via a third party application - either through a Payment Initiation Services Provider (PISP), Account Information Service Provider (AISP) or by providing embedded financial products or banking as a service solutions (i.e. financial services via an Application Programming Interface (API)) - is it permitted for the PSP to delegate the application of 2-Factor Authentication (2FA) to the third party?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2020_5643
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Meaning of ‘intragroup’ for the purpose of reporting in COREP template C 67.00

What is the scope of ‘intragroup counterparties’ for the purposes of classification of funding in COREP template C 67.00, column 050 (Product Type)? Is particular, can funding from a parent entity in a third country be considered ‘intragroup’?

  • 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: 2020_5638
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

v3078_m - Maximum Amount of Guarantee Given

Should the maximum amount of guarantee given reported in F_09.02 be capped at the carrying amount or nominal amount after deduction of provisions of the related exposure?

  • 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: 2020_5634
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Collateral obtained by taking possession: Classification as Residential or Commercial

Clarification of the applicable criteria for the classification of foreclosed asset as Residential or Commercial in FINREP templates

  • 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: 2020_5632
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Treatment of non-performing exposures underlying a CIU

Could you clarify if non-performing exposures underlying a CIU should be subject to deductions in accordance with point (m) of Article 36(1) of CRR when using the look-through approach in accordance with Article 132a(1) of CRR or the mandate based approach in accordance with Article 132a(2) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5629
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Is the activity of pension fund administrators included in the "Portfolio management and advice" and thus, pension fund administrators qualify as financial institutions?

Is the activity of pension fund administrators included in the "Portfolio management and advice" and thus, pension fund administrators qualify as financial institutions?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5628
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 07/09/2022