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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.

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List of Q&A's

Cash variation margin received in the same currency of settlement of the derivative contract

Second sub para. of Art. 429a(3) of the leverage ratio Delegated Regulation indicates that: "For the purposes of point (c) of the first subparagraph, where the derivative contract is subject to a qualifying master netting agreement, the currency of settlement means any currency of settlement specified in the derivative contract, the governing qualifying master netting agreement or the credit support annex to the qualifying master netting agreement.” As "currency of settlement" is not sufficiently specified and differs from standard market documentation terminology, we we would request to provide further explanation on the interpretation of “currency of settlement”.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2016_2570
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of ECB LTRO in table 2A2 (P 02.02) and validation rule v4135_m

Should ECB LTRO transactions be strictly reported in table P 02.02 in row 010 as a repo transaction?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2016_2569
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 28/07/2017

Reporting of funding, obtained to supply credit to the real economy, and validation rule v4137_m

Should in table P 02.02, row 030, only the obligations be reported, which arise through the issuance of debt securities or is the reporting of loans from multilateral financial institutions and public financial institutions expected as well?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2016_2568
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 15/06/2018

Power of the resolution authority to transfer back

How should the transfer back procedure be applied in the context of the sale of business tool?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2565
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Clarification on Article 36(6)(a)

How should the term "updated” referred to in Article 36(6)(a) of Directive 2014/59/EU (BRRD) be interpreted?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2564
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Intra-group financial support consideration

According to Article 23 Directive 2014/59/EU (BRRD), the intra-group financial support may be granted if there is a reasonably prospect that the beneficiary party pay the consideration. Should this consideration only take a pecuniary form?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2563
  • Topic: Intra-group financial support
  • Date of submission:
  • Published as final Q&A: 05/02/2016

Recovery plans for subsidiaries that are not institutions

Can the requirement to draw up and submit an individual recovery plan under Article 7(2) of Directive 2014/59/EU (BRRD) be imposed upon subsidiaries that are not institutions (e.g. financial institution, financial holding company)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2562
  • Topic: Recovery plans
  • Date of submission:
  • Published as final Q&A: 28/01/2022

Benchmarking

With regard to Annex I - C 103.00 we see that EBA requires data that the bank already reports regularly via COREP. For some of them, we see a so-called legal reference. Examples: 22 120 13 Collateral Value 22 140 13 Maturity 22 160 13 Provisions non-performing exposures The question is: do we comply to the EBA Benchmark requirements if we report equally to the regular COREP report? Or should we use these data and follow the legal reference to calculate it in a deviating way?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2561
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Splitting exposures

In the case that an exposure has attributes that it can be assigned into various exposure classes, may it be divided into two exposure classes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2560
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Classification of exposures for which an IRB bank uses the standardised approach, into IRB exposure classes (Article 147 CRR)

Is there any regulation stipulating that for exposures where an IRB bank uses the standardised approach, these "standardised" exposures have to be classified into exposure classes valid for the standardised approach (Article 112 Regulation (EU) No 575/2013 (CRR)).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2559
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/06/2016

Interaction of the EBA Opinion on the MDA and Article 92 Regulation (EU) No 575/2013 (CRR)

Where a bank does not have sufficient subordinated debt in issue to fulfil its minimum 1.5% Tier 1 and 2.0% Tier 2 requirement, it may need to use a higher quality form of capital to fulfil these requirements.To the extent a bank has to assign CET1 to fulfil shortfalls in its minimum Tier 1 and Tier 2 requirements, can this CET1 also be applied to meet Pillar 2 and Combined Buffer requirements for the purpose of calculating the MDA? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2552
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 26/08/2016

The definitional references for rows 030 and 040 of Table 1C of Template P 01.03 refer to the Basel 3 Monitoring template instead of the Delegated Act on LCR

Should the data for rows 030 and 040 of Table 1C of Template P 01.03 be reported based on the Delegated Act, instead of the data based on the Basel 3 Monitoring templates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2016_2551
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Clarification of the geographical scope of the benchmark portfolios

Annex I, template C103, Column 030: When 'not applicable' is stated for geographical location,should we report the aggregate of the 24 countries listed or the aggregate of the bank's worldwide portfolio?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2550
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/06/2016

Liquidity waiver for institutions controlled by EU parent financial holding company

Regarding the application of Article 8 (1) of Regulation (EU) No 575/2013 (CRR), can it be considered to extend the option to accept a liquidity sub-group to cases where the parent company is a EU parent financial holding company owning a single credit institution or a single investment firm, if all the conditions laid out in article 8 (1) of Regulation (EU) No 575/2013 (CRR) are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2549
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Trades receivables towards Central Banks

Could you clarify why in the FIN 5 template, it is not possible to put an amount in the cell « Trades receivables towards Central Banks” (Row 30 Column 10)?

  • 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: 2015_2546
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Deduction from own funds of items entered as assets that are not yet included within equity

If an institution enters an asset (e.g. at Equity valuation of a holding in a Financial Sector Entity (FSE) or increasing the amount of a deferred tax asset) through the profit and loss statement (P&L), the corresponding profit is not eligible for own funds before it is audited and officially approved (or in case of interim or year-end profits before it is audited and recognition is approved by the competent authority).However, the deduction amount (e.g. holdings in FSE or DTAs) has formally increased and would lead to an immediate higher deduction amount. If this was the case, it would represent the deduction of gains that are not yet recognized in the own funds of the institution. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2544
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/10/2017

Correct application of credit conversion factors in relation to credit substitutes and shipping guarantees

According to Annex I Classification of off-balance sheet items:a) Paragraph 1. (a) guarantees having the character of credit substitutes are guarantees for the good payment of credit facilities. These guarantees bear full risk, therefore CCF of 100% is applied as stated in Article 111. Could you provide more examples or a definition of credit substitutes?b) Paragraph 2. (b). (i) shipping guarantees: could guarantees for payment of delivered goods and services be considered shipping guarantees?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2543
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/12/2016

Liquid assets underlying sold call options

Should bonds underlying call options (either American or European expiring within 30 days; with exercise mode physical delivery) written by the institution be considered as used in hedging strategies, thus excluding them from the holding of liquid assets in the context of LCR reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2542
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 25/08/2017

Prices for Various Lengths of Funding-currency spreads

We would like to seek further guidance on whether the EBA expects firms to calculate spreads for all currencies, which would then be used to calculate the total, or if the EBA would accept reporting for material funding only?

  • 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: 2015_2538
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

EAD Template C 105.01

In Column 040 EAD of template C 105.01 the EAD is required. Is it the entire EAD for the respective internal model on institution level irrespective of portfolios or do we have to calculate the EAD for each portfolio which is assigned to the respective internal model? On reporting date 31.12.2015 these would be the portfolios mentioned in template C 103.00.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2015_2537
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission: