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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.

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List of Q&A's

Non material losses

The definition of what is a non-material loss is not defined within Article 472 of Regulation (EU) No 575/2013 (CRR); is it possible to clarify what ‘material’ / 'non-material' is? Can you advise how- if applicable- such non-material losses are treated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_448
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Original Exposure pre-conversion Factors

The draft ITS on Supervisory reporting state that the Exposure value (for on-balance sheet exposures) equals to the exposure value without taking into account value adjustments and provisions, conversion factors and the effect of credit risk mitigation techniques. However, article 111(1) states that "The exposure value of an asset item shall be its accounting value remaining after specific credit risk adjustments". Additionally, the accounting value of an exposure is net of certain value adjustments e.g. non-recoverable income, etc. If for example, we have a customer loan with the following data: A. Balance: 100 B. Non-recoverable income -10 (usually from non-accrual status) C. Gross Accounting value (A+B) 90 D. Provisions -20 E. Net Exposure (C+D) 70 What is the Original Exposure pre-conversion Factors, A or C?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_446
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Contradiction between CRR and Draft ITS on Supervisory Reporting of Off-balance items

Following the CRR annex I we should report off-balance: (b) credit derivatives;(c) acceptances;(d) endorsements on bills not bearing the name of another institution;(e) transactions with recourse (e.g. factoring, invoice discount facilities);(g) assets purchased under outright forward purchase agreements;(j) asset sale and repurchase agreements as referred to in Article 12(3) and (5) of Directive 86/635/EEC; Following the Draft ITS on Supervisory Reportingparagraph 60 these items should never be reported off-balance

  • 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: 2013_442
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Reporting LE in accordance with Art 392, 20 largest exposures according to last sentence of Art 394(1), 10 largest exposures to institutions and 10 largest to UFE according to Art 394(2)

Do we have to report 4 separate lists? i.e. List 1: LE1, LE2 and LE3 for large exposures defined in accordance with Art 392 (ref. Art 394(1)), including LE exempted from the application of Art 395(1) List 2: LE1, LE2 and LE3 for 20 largest exposures according to the last senctence of Art 394(1), excluding those exempted from the application of Art 395(1) List 3: LE1, LE2, LE3, LE4 and LE5 for 10 largest exposures to institutions according to Art 394(2), including LE exempted from the application of Art 395(1) List 4: LE1, LE2, LE3, LE4 and LE5 for 10 largest exposures to unregulated financial entities according to Art 394(2), including LE exempted from Art 395(1) In which case a particular group of connected clients may show up in several lists (e.g. group XXX shows up in list 1 and in list 2) OR do we have to provide one instance of LE1, LE2, L3, LE4, LE5 such that a particular group of connected clients shows up only once in LE1, LE2 etc.?

  • 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: 2013_441
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Reporting of liquid assets as per annex III CRR

In the C51.00 liquid assets template, should columns 030 and 040 be greyed out for rows 340 to 360 and columns 010 and 020 be greyed out for rows 370 to 390?

  • 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: 2013_439
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Reporting of liquid assets as per annex III CRR

Should items under lines 3.1, 3.2, 3.9 and 3.10 in section 3 of the C51.00 template be reported up to their amount, as items under 1.1, 1.2, 1.5 and 1.6 lines, or at their market value as specified in the template?

  • 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: 2013_438
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Liquidity-sub group

In Article 8 (1) of Regulation (EU) No. 575/2013 (CRR), it is stated, that institutions may fulfill the liquidity requirements on a liquidity-sub-group level, if the subsidiaries are located in the Union resp. Article 8 (3) deals with liquidity sub-Groups in several member states. Is it also possible to build-up a liquidity sub-group, if one of the subsidiaries is not located in the Union, but the country is member of the EWR (esp. EFTA member like Liechtenstein, Iceland and Norway)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_437
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/06/2014

Scope of application of FINREP

Our question concerns Article 99(4) of Regulation (EU) No. 575/2013 (CRR). Does it empower national competent authorities to determine, in respect of smaller non-systemic institutions that for whatever reason use international accounting standards/ IFRS (and thereby fall under paragraph (2)), that such institutions need not be required to report financial information as envisaged in Article 99 (2)? This would be on the grounds that such information is not necessary either to obtain (i) a comprehensive view of the [individual] risk profile of such institutions; or to obtain (ii) a view of the systemic risks posed by such institutions [collectively] to the financial sector or the real economy.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_433
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/10/2014

Validation Rules

Can the validation rules (in Annex XV, from row 1160 till 1178) for the template C61.00 "Stable funding - items providing stable funding' be deleted?

  • 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: 2013_431
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Highly leveraged obligors

How to define/identify 'highly leveraged obligors' under Article 180(1)(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_430
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 25/07/2014

Interpretation of Article 325b of Regulation (EU) No 575/2013 (CRR)

1. Are the conditions set out in Article 325b (2) CRR conditions that have to be simultaneously met with respect to every single institution and undertaking (parent and subsidiaries) no matter whether it holds positions that shall actually be offset on a consolidated basis? 2. Analogously, are the conditions set out in Article 325b (3) CRR conditions that have to be simultaneously met with respect to every single undertaking in a third country no matter whether it holds positions that shall actually be offset on a consolidated basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_429
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 06/06/2014

Scope of "undertaking" in Article 325 (1) of Regulation (EU) No 575/2013 (CRR)

Does the term “undertaking” in Article 325 (1) of CRR refer to financial sector entities as well as other legal business entities outside the financial sector? If not, to which does it refer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_428
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 06/06/2014

Gross amount of intangible assets

Should the institution report in COREP other intangible assets in gross amount not net as today it's 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: 2013_423
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Stock financing

Could you please clarify if the positions that are purely ‘stock financing’, as defined in Article 3(1)(l) of Directive 2006/49/EC, but not defined in Regulation (EU) No. 575/2013 (CRR), may be excluded from the calculation of own funds requirements for commodities risk under Part three, Title IV, Chapter 4 of the CRR, as was allowed under Directive 2006/49/EC.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_422
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 28/03/2014

Conversion of the total amount owed to institution from national currency to EUR

Which exchange rate should the institution use to convert the amount owed to institution (mentioned in Article 501 point 1)? Should it be converted to EUR each day with exchange rate from this day or should the exchange rate be fixed, for example from the day when the product was sold?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_417
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 28/05/2014

The meaning of the "amount owed to the institution"

How should institutions understand the "amount owed to the institution" under Article 501(2)(c)(1) in case of off-balance sheet exposures to customers that haven’t yet been used? Is it the exposure value (as understood in Article 111) or the nominal value of such product (for example credit line)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_416
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/01/2014

Unfunded credit protection; adjusting PD or LGD; coefficient of correlation large financial sector entities or unregulated entities

1. Under Article 161(3) of CRR, can unfunded credit protection be recognised by adjusting PD or LGD, but not both? 2. If the institution has a subordinated exposure to an obligor, and a guarantee is recognised by adjusting the PD under Article 161(3), is it allowed to also adjust the LGD for the subordinated exposure and use a LGD associated with a senior claim on the obligor or guarantor, if the guarantee would represent a senior claim on the guarantor (compare with Article 236(1)). 3. (a) If an institution is recognising unfunded credit protection by adjusting or substituting the PD under Article 161(3) for an exposure for which article 153(2) is not applicable, should it also adjust the coefficient of correlation from the obligor to the guarantor, including applying the multiplier of 1.25, in case unfunded credit protection has been received from a large financial sector entity as defined in Article 142(1)(4), or unregulated financial entity as defined in Article 142(1)(5). (b) If an institution is recognising unfunded credit protection by adjusting or substituting the PD under Article 161(3) for an exposure for which article 153(2) is applicable, should it also adjust the coefficient of correlation (multiplied by 1.25), in case unfunded credit protection has not been received from a large financial sector entity as defined in Article 142(1)(4), or unregulated financial entity as defined in Article 142(1)(5), but, for example, from a large corporate or sovereign. 4. (a) If an institution is recognising unfunded credit protection by adjusting the LGD under Article 161(3) for an exposure for which Article 153(2) is not applicable, should it also adjust the coefficient of correlation, including applying the multiplier of 1.25, in case unfunded credit protection has been received from a large financial sector entity as defined in Article 142(1)(4), or unregulated financial entity as defined in Article 142(1)(5). (b) If an institution is recognising unfunded credit protection by adjusting the LGD under Article 161(3) for an exposure for which Article 153(2) is applicable, should it also adjust the coefficient of correlation (multiplied by 1.25), in case unfunded credit protection has not been received from a large financial sector entity as defined in Article 142(1)(4), or unregulated financial entity as defined in Article 142(1)(5) , but, for example, from a large corporate or sovereign.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_415
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/02/2016

Conditions taken into account to use the factor 0,7619

Should an institution stop using the factor 0.7619 as soon as the amount owed to the SME enterprise exceeds 1.5m EUR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_414
  • Topic: Credit risk
  • Date of submission:

COREP LE template

1.On the LE template what is “Code” – the guidance notes seem to suggest that the code will depend upon the national reporting system, unless a uniform codification is available in the EU. We dont believe there is a uniform codification - What should firms do with this box? 2.On LE what is sector of counterparty – It refers to FINREP economic sector but as we do not implement FINREP we are not sure what this is? And how should non FINREP firms report? 3.On LE what exposure should advanced firms be reporting? sEEPE or EEPE. This could vary from submission so do PRA want LE exposure reported in line with capital requirements or just in one way? 4.On LE what does expected maturity mean? Is it the residual maturity? 5.On LE where do we report other receivables and cash at bank? 6. How are firms that have core Uk group and non core LE groups supposed to report on the COREP LE template – do we report as if we have the waivers under the LE COREP template 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)
  • ID: 2013_412
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 21/03/2014

Publication of administrative penalties

Does the requirement to publish the administrative penalties (Article 68 of Directive 2013/36/EU (CRD)) include publishing supervisory powers listed in Article 104?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_411
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 26/09/2014