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List of Q&A's

Foreign Exchange Risk – Interest Rate Swaps and Forward Rate Agreements in C 22.00

Are Interest Rate Swaps and Forward Rate Agreements, where only one currency is involved, relevant for reporting FX risk in the template C 22.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6357
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 23/02/2023

C 34.06 - Counterparty with dual Counterparty Type

In column c0050, a bank should report the type of the counterparty with the following options: QCCP, non-QCCP and No CCP. Where a counterparty which acts as a QCCP for a number of netting agreements and transactions and at the same time acts as a No CCP as well for different netting agreements and transactions, should the counterparty be recorded (a) twice in C 34.06, its total values reported in columns 0070 to 0130 split between the two different types i.e. one line as a QCCP and another as a No CCP; or (b) once with its total exposures be populated in a single line and the counterparty type in c0050 to be populated with QCCP?

  • 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: 2022_6356
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/10/2022

Calculation of “Total exposure” and other concepts in G 01.00 (G-SII indicators and EBU items)

It is not clear from the instructions how to calculate the total exposure measure (and other measures) and their relation to the leverage ratio exposure measure reported in C 47.00.

  • 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: 2022_6355
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Standardised Approach for Counterparty Credit Risk (SA-CCR) exposure value for a netting set subject to a margin agreement

For the calculation of the SA-CCR EAD according to the CRR2, does one need to calculate the EAD according to the CRR2 Art 275, 278 (that results into an EAD of €41m in the example), or does one need to apply the BCBS CRE 52 guidance (that results into an EAD of €378m in the example)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6354
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

Validation rule v6053_m

According to the validation rule v6053 {F 01.02, r0220, c0010} = xsum ({F 09.01.1, (r0010, r0090, r0170, c0040, c0050, c0060, c0065, c0110)}) there must be an exact match between Row 220 “Commitments and guarantees given” of F 01.02 'Liabilities” and the sum of the provision on off balance sheet exposures of F 09.01.1. 'Off-Balance sheet exposures”. Is it correct to assume that such VR would not be applicable if an entity of the Group has provision on off-balance sheet exposures and, at the reference date, falls under IFRS 5 having as a consequence a representation only on row 0290 “Liabilities included in disposal groups classified as held for sale” instead of row 0220 “Commitments and guarantees given” F 01.02 'Liabilities”? Same phenomenon applies also for validation rule v1385_m: {F 01.02, r0220, c0010} = xsum({F 20.05.b, c0030, (r0010-0030, sNNN)})  

  • 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: 2022_6353
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Complusory reserves in F 01.01

In one of countries where we operate, Compulsory (Minimum; Obligatory) reserves are split in to non-restricted (daily due) and restricted (up to one month => “The maintenance period begins on the second Wednesday of a month and lasts to the day preceding the second Wednesday of the following month”). Shall we present them together in a Template F 01.01 row 0030 column 0010 => "Cash balances at central banks", or restricted part should be presented as Loans and Advances (for example as Loans and Advances at amortised cost => Template F 01.01 row 0183 column 0010)?

  • 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: 2022_6352
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 07/11/2022

Calculation of the CET1 deduction for non-performing exposures (NPEs)

Which date shall be used to determine the applicable factor that is used to calculate the amount determined in Article 47c(1)(a) CRR when the terms and conditions of a non-performing exposure, which was originated prior to 26 April 2019, have been modified by the institution in a way that increased the institution's exposure to the obligor and  the counterparty defaulted before the initial origination of the exposure? The date on which the counterparty initially defaulted or the date on which the exposure was initially originated or the date on which the terms and conditions of the NPE have been modified by the institution in a way that increased the institution's exposure to the obligor?     Additionally, which date is supposed to be considered if the default of the exposure/counterparty occurs after the initial date of origination of the exposure and before an increase in amount of exposure? The date of default or the modification date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6351
  • Topic: Own funds
  • Date of submission:

Interest-income on credit impaired financial assets (template F 16)

Template F 16, r0280, of which: interest-income on credit impaired financial assets: if a financial asset was credit impaired during for example Q1, Q2, and Q3, but during Q4 became performing again, should we still report the interest-income reflected on this row in the Q4-reporting?

  • 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: 2022_6350
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 28/04/2023

C40 LR1 report Column 0010, 0020

There is a clarification given on Single rule Q & A 2014_1131 that there are 2 accounting standards. IFRS and national GAPP. IFRS guidelines for FINREP reporting Annex XI,  For the purposes of Annexes III and IV as well as this Annex, "the carrying amount" means the amount to be reported in the balance sheet. The carrying amount of financial instruments shall include accrued interest. Under the relevant national GAAP based on BAD, the carrying amount of derivatives either shall be the carrying amount under national GAAP including accruals, premium values and provisions if applicable, or it shall be equal to zero where derivatives are not recognised on-balance sheet.For the purposes of Annexes III and IV as well as this Annex, "the carrying amount" means the amount to be reported in the balance sheet. The carrying amount of financial instruments shall include accrued interest. Under the relevant national GAAP based on BAD, the carrying amount of derivatives either shall be the carrying amount under national GAAP including accruals, premium values and provisions if applicable, or it shall be equal to zero where derivatives are not recognised on-balance sheet. Thus, IFRS does not permit accounting balance sheet value to be reported net of mitigation of collaterals or margin amounts. In general GAAP accounting also does not permit accounting balance sheet value to be reported net of mitigation of collaterals or margin amounts. As the guidelines are applicable to SFT positions, net amount of cash collateral or security have to be reported. The same are applicable for other on balance sheet positions to be reported in C40, in Column 0010, 0020. Keeping in view of the above, request for clarification what is likely to be the amounts to be reported in Column 0010 from Column 0020.    

  • 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: 2022_6349
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 25/01/2023

[none]

When Institutions calculated the value of exposure value pre-CRM according to Standard approach for counterparty credit risk should it consider as for every counterparty there aren't any margin agreement and collateral exchanged (Variation Margin)?

  • 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: 2022_6348
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/10/2022

Instruments contemplated by Article 104(2)(i)

Pursuant to Art 104(2)(i) CRR, what is meant by 'options, or other derivatives, embedded in the own liabilities of the institution or from other instruments in the non-trading book that relate to credit or equity risk'. Does that mean capital instruments with embedded optionality like hybrids?   Kindest, Scott

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6347
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

C 70.00 (AMM)

For new or renewed operations in C70-Template, we reported the carrying amount of the operation, namely, the principal amount of the operation plus the amount of accrued interest not yet paid to the client. However, for operations due or canceled early in the month, we only inform the principal amount of the operation and not the interests that have already been paid to the client. Is this interpretation correct regarding the consideration of interests?

  • 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: 2022_6346
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

Encumbrance duration of reverse repo in NSFR when the received collateral has been sold short

When the received collateral through a reverse repo has been sold outright, what should the encumbrance duration for the reverse repo be?

  • 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: 2022_6345
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/01/2023

language versions

In case of discrepancies between text of English version of EBA Guidelines on outsourcing arrangements and its other language versions published on EBA website, which version should prevail - English or local one?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/02 - Guidelines on outsourcing arrangements
  • ID: 2022_6344
  • Topic: Internal governance
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

See previous question Bank of Lithuania, question 2020_5463

See Question 2020_5463 which was submitted on 24/08/2020. Could you please let me know the timing of answering this question?

  • Legal act: Regulation (EU) 2015/847 (WTR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6343
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 08/02/2023

Amount of holdings to be reported (CA4)

Regarding the reporting of Direct indirect and synthetic holdings by the institution of Common Equity Tier 1, Additional Tier 1 and Tier 2 instruments of financial sector entities in template C 04.00 (CA4), it is not clear whether the full holding amount is to be reported in template C 04.00 (CA4), rows 0230 to 0643, or only the deduction amount.   This question applies both where the reporting institution's holdings are above the threshold limit and where they are within threshold limit: Is full holding amount to be reported?

  • 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: 2022_6342
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

LCR treatment of deposits placed with other credit institutions

What is the LCR treatment of deposits placed with other credit institutions where the depositing credit institution neither reconciles with the deposit-receiving institution nor further examines the nature of the deposit?

  • 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
  • ID: 2022_6341
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 21/12/2022

Documentation language - Do IRB documentation need to be in English?

Does IRB documentation need to be in English? Is there any official guideline on what documentation is acceptable in non-English language?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6340
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Article 28(1) of Regulation (EU) 2015/61 on LCR

Can You please explain, what is meant by "Those deposits shall be reported in two different rows depending on whether or not the entire amount of the deposit is covered (by a Deposit Guarantee Scheme or third country equivalent Deposit Guarantee Scheme)" described in COMMISSION IMPLEMENTING REGULATION (EU) 2021/451, Annex XXV, part 2 (Outflows), rows 0240-0260. Could you give an example?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6339
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Aggregation of retail deposits for checking the criteria for "retail deposits subject to higher outflow rates"

If a natural person has an account at the bank as a natural person and, at the same time, he/she is an owner of a legal entity, which qualifies as an SME, and also has a separate business account at the same bank as a legal entity, shall the accounts of both the natural person and the legal entity aggregated when checking the total deposit balance against the threshold of EUR 500 000? If yes, what shall be the level of legal entity ownership (e.g. 100%, more than 50%, etc.) in order to combine the natural person and the legal entity?

  • 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
  • ID: 2022_6338
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022