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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

Template F 40.1 c095

What should be reported in template 40.1 c 095 "sector of investee"? The designation "sector" is misleading. The explaintation of the column ITS part 2.124 (h) refer to ITS part 1.25: “Sector of investee” means the sector of counterparty as defined in paragraph 25 of Part 1. But the ITS part 1.25 has no relation to template 40.1. The ITS part 1.23 explains that Financial assets shall be distributed among the following classes of instruments: “Cash on hand”, “Derivatives”, “Equity instruments”, “Debt securities”, and “Loan and advances”. Is this a wrong referencing? What should be reported in this column? 1) Should be reported the counterparty, which is described in ITS part 1.35? If yes than in our opinion the counterparty Central banks, General governments and Households must be excluded? 2) Should the sector / branch of the entity be reported in this column? If yes what is the difference between 095 and column 100 "Nace Code"?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Eligible capital under Art. 4(1)(71)(a) and (b) CRR

The position C 04.00, r 220 (ID 11) "Eligible capital for the purposes of qualifying holdings outside the financial sector and large exposures" conflates two distinct definitions of "eligible capital", i.e. eligible capital for the purposes of Title III of Part Two CRR (cf. Art. 4(1)(71)(a) CRR) and eligible capital for the purposes of Art. 97 and Part Four CRR (cf. Art. 4(1)(71)(b) CRR). The two definitions of eligible capital differ with regard to the deduction under Art. 36(1)(k)(i) CRR and, if applicable, the resulting limitation in the eligibility of Tier 2 capital (which may not exceed one third of Tier 1 capital for the purposes of both lit. (a) and lit. (b)). Hence it is necessary to split the position into two positions.

  • 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)

Validations between F 13.01 and F 05

According to the Final Q&A 2013_512 (posted on 21/03/2014), “the amounts to be reported in templates F 05.00 and F 13.01 diverge. Within F 05.00, the outstanding amount of the loans shall be reported, while in F 13.01, it is the amount of the collateral that shall be declared capped by the amount of the loan”. “(…) That means that the validation rule v1074_m shall be expressed with the sign “<=”, that is, sum({F 13.01, r010, (c010-020)}) <= sum({F 05.00, r090, (c020-060)}”. We understand that if validation rule v1074_m is corrected, other validations that relate templates F13.01 and F05 with the sign“=” should be also modified. Would it be also necessary to correct the sign “=” on validations that are listed below? v1076_m v1077_m v1079_m v1080_m v1082_m v1083_m v1085_m (See example of validations v1076_m or v1077_m in attached document)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Maturities in Large exposure report (LE4; top 10)

How should we interpret and apply the reference to the instructions of the maturity ladder template of the additional metrics on liquidity in Annex IX 18Instructions for reporting large exposures and concentration risk 19?

  • 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)

CA3 - rows 110 and 120

CA3 row 110 and 120 only need to be populated if a competent authority decides that a bank has to meet a higher target total capital ratio (r120) or has an impact on the total capital ratio (r110). Can you please advise, whether these cells need populating or 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)

Validation Rule v3684_s,v3693_s,v3695_s

The fields within the scope of the three rules deliver values for various transitional adjustments to different types of capital.The three rules(v3684_s,v3693_s,v3695_s ) state that these values must be positive. There may be a problem with the sign, as some of the values referenced per CA1 could be negative.As examples I hereby include: -v3684_s : CA1 - field [730,010] Other transitional adjustments to AT1 Capital ; field [960,010] Other transitional adjustments to T2 Capital -v3693_s : CA5.1 - field [140,060] Deductions; field [180,060] IRB shortfall of provisions to expected losses; Are these rules correct ?(perhaps just the scope of the rules needs adjusting)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

LR1 on alternative treatment of the exposure measure - accounting balance sheet value

Does the "accounting balance sheet values" as reported in LR1 include credit risk mitigation effects? The difference between column 010 (accounting balance sheet value) and column 020 (accounting value assuming no netting or other CRM) will then be based on credit risk mitigation effects (crm/netting)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

FINREP F 40.2

In the Q&A 2013_93 und 2013_344 you have published clarification regarding the requirements of table 40.2. You stated that all securities issued by an entity included in the accounting scope of the group which holds the securities in their individual balance sheet, shall be reported. Table F 40.02 is to be viewed from the point of view of the entity holding the equity instruments that are included in the accounting scope of consolidation (i.e. subsidiaries, joint ventures and associates). Shall this table comprise only investments/securities that are hold by more than one holding company (Option 1) or each investments / security within the accounting scope of consolidation (Option 2). Thus is the base of investments / securities equal to table 40.1? Please see the example in the excel-sheet.

  • 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)

F 09.02 & F 13.01: Maximum amount of the guarantee that can be considered

Please we would like to know what the differences are between the reporting of the "maximum amount of guarantee that can be considered" in templates F 09.02 and F 13.01. Why are these concepts not equal?In question ID 2013_338 it is stated:(...) since for F 09.02, the amount is the maximum amount the counterparty could have to pay if the guarantee is called on, and in table F 13.01, the amount of guarantee shall not exceed the carrying amount of the related loan.

  • 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)

FINREP reporting requirements

If an institution is currently not within the scope of FINREP (i.e. not subject to article 4 of Regulation (EC) No. 1606/2002), but may fall within the scope of FINREP in the future, what would be the institution's first reporting reference date for FINREP?

  • 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)

Commencement of 3-month period when CCPs cease to meet certain conditions

Should the 3-month period available under Regulation (EU) No 575/2013 (CRR) Article 311, where a firm may continue to treat a CCP as QCCP following confirmation that the CCP no longer meets the conditions for authorisation or recognition, apply: (1) From the earlier of the date of ESMA negative confirmation of authorisation or recognition or from the end of the transitional period available for CCPs under CRR Articles 497(1) and 497(2); or (2) Only after ESMA has made an initial positive assessment of authorisation or recognition and the CCP fails to meet those conditions at a later date?

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

F 46.00 - changes in equity - other equity and total comprehensive income

Cell r200-c040 is marked as grey in FINREP table 46 and consequently this cell is not to be filled in. However, if a financial institution has classified "Total comprehensive income" in changes in equity under "Other equity" in its financial reporting based on IFRS, where are we to put this number?

  • 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)

Annex V - FINREP - Table 31.1 Related parties

In Annex V it is stated in paragraph 120 that "institutions shall include the portions of balances and transactions with joint ventures and associates of the group to which the entity belongs that have not been eliminated when either proportional consolidation or the equity method is applied." If a financial institution uses equity method for consolidation purposes for assiciates of the group, does this mean that column 030 in table F 31.01 is to be left empty?

  • 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)

CR IRB (C08.01 and C08.02) template column 010 and CR GB (C09.02) column 080

In column 010 of templates C08.01 and C08.02 and column 080 of template C09.02, is the obligor PD reported before CRM effects and floors or after CRM effects and floors which is used in the RWA calculation reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements

Non Performing Loans at group levels.

Clarification is requested as to when group (connected) accounts should be downgraded to the Non Performing category (NPL) when only one party from within this group classifies as an NPL (refer to the 2nd part of para. 155). Should group facilities be downgraded: 1. When exposures past-due by more than 90 days represent 20% of the gross carrying amount of a singly debtor (one party within group entities) or 2. When exposures past-due by more than 90 days represent 20% of the gross carnying amount of the total group exposure? or is this left at the discretion of the credit institution? 

  • 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)

Content of “accumulated changes in fair value due to credit risk” in template F 16.05

Column 020 of template F 16.05 is labeled as “Accumulated changes in fair value due to credit risk”, whereas the respective instructions (paragraph 100 of part 2 of Annex V of the ITS on supervisory reporting) reads “Institutions shall report the net realised and unrealised and the amount of change in fair value in the period due to changes in the credit risk (own credit risk of the borrower or issuer).”. We would like to get confirmation that the instructions shall be followed and that the use of the word “accumulated” in the second column of F 16.05 is a typo.

  • 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)

Loans collateralized by immovable property in F 05.00 and F 13.01

Do loans collateralized by immovable property in template F 05.00 contain only residential and commercial immovable property, like in F 13.01, or are they open to other collateralized immovable property (those which do not meet the definition of residential and commercial provided by CRR)? If the former, are those loans collateralized by other immovable property reported as other loans collateralized?

  • 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)

Validation Rule v0629_m

Can rule v0629_m be valid in any case? Namely, in some cases (see background information) the own funds requirements for foreign exchange stipulate that the foreign exchange risk be calculated as the sum of its overall net foreign exchange position and its net gold position in the reporting currency, multiplied by 8 %, not by 12,5%, which is what the rules, in effect, validates.

  • 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)

Non-performing exposures - Cash balances at central banks, Non-current assets held for sale

Does template F18.00 DEBT INSTRUMENTS AT AMORTISED COST (rows 010 to 180) include Cash and cash balances at central banks portfolio? Does template F18.00 DEBT INSTRUMENTS AT FAIR VALUE other than HFT (rows 190 to 320) include Non-current assets and disposal groups classified as held for sale?

  • 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)