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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

Adequacy of the validation rule v10684_m - Instruments not at FVPL

v10684_m foresees a reconciliation between F 12.01 and F 02.01 in respect of gains/losses from financial instruments not at FVPL. Why is this validation rule expected to work, considering that (a) it encompasses debt instruments at amortized cost, which are identified as purchased or originated credit impaired assets (POCI) or are attributable to Stage 3 at the date of de-recognition and (b) it encompasses debt instruments at fair value through other comprehensive income?

  • 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_6337
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/01/2023

Definition of electronic money

Does the wording “accepted by a natural or legal person other than the electronic money issuer” in the definition of electronic money (article 2.2) imply that a third party (payee) must become the holder of the electronic money as such and thus that there must be a direct contractual arrangement between the e-money issuer and all payees (obligating the payees to accept the issued e-money as a means of payment and granting the payees a right of redemption of the e-money)?  or should the criterion that a third party must “accept the electronically stored monetary value” be considered to be met where a third party payee accepts our customer’s payment with a card that is backed by the customer’s e-money (as per the description above), regardless of the fact that the payee will not become a holder of the issued e-money as such?

  • Legal act: Directive 2009/110/EC (EMD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6336
  • Topic: Not applicable
  • Date of submission:

Definition of small and non-complex institutions and its applicability to SSM significant institutions

Does an institution that has been determined by the ECB as being significant within the meaning of Art. 6 (4) SSM Regulation* due to its membership to a group of significant institutions according to Art. 40 (2) of SSM Framework Regulation** qualify as small and non-complex institution as provided by Art. 4 no. 1 (145) of Regulation 575/2013? *Council Regulation (EU) No. 1024/2013 conferring specific tasks on the ECB concerning policies related to the prudential supervision of credit institutions ** Regulation (EU) No. 468/2014 of the ECB establishing the framework for cooperation within the Single Supervisory Mechanism between the ECB and national competent authorities and with national designated authorities (ECB/2014/17)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6335
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

NSFR - Reporting of certain committed facilities in C 80.00

  Should committed facilities (Annex XII, C 80.00, r1060), the residual contractual maturity of which is equal or longer than six months, but which can be drawn down at any time regardless of their (residual) contractual maturity, be reported in column 0010?

  • 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_6334
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 25/01/2023

wrong column in general remarks 3.3.6.1 / 84

Does columns references are correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6333
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/10/2022

missing articles accordance into columns 0010 instructions

Does institutions shall use the exposure value before CRM in accordance with only the Article 166 CRR ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6332
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/10/2022

Collateral swaps with underlying collateral baskets

How to create combinations for collateral swaps with underlying collateral baskets for a special case where no asset left for one leg? Please see more details with the example. 

  • 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_6331
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 20/01/2023

Reuse of collateral in a repo transaction with collateral substitution rights

Can a bank record an inflow for a reverse repo with a residual maturity of up to 30 days under the LCR, where collateral is being funded in a repo with a residual maturity of more than 30 days, where collateral is allocated on an automated basis and managed by a third party (ie triparty repo), and where the repo has automatic rights of substitution for collateral of the same or better HQLA classification?

  • 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_6330
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Recording of necessary documentation in relation to the disbursement of the loan

In relation to  46 of the EBA Guidelines on loan origination and monitoring, what is expected in relation to the 'recording of necessary documentation in relation to the disbursement of the loan', specifically in relation to adherence to the institutions' obligations towards AML/CTF requirements?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring
  • ID: 2022_6329
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

How shall open maturity repos be reported in C 81.00 and with which ASF factor ?

It is not totally clear what the term 'unless otherwise specified' in Article 428k of Regulation (EU) No 575/2013 CRR, as amended by Regulation (EU) 2019/876, means for an open repo. Does the use of the term 'unless otherwise specified' in the sentence 'unless otherwise specified in Articles 428l to 428o, all liabilities without a stated maturity, including short positions and open maturity positions, shall be subject to a 0 % available stable funding factor' mean that an ASF factor corresponding to the type of counterparty must be applied as per the article 428l to 428o CRR first?  One answer is to allocate to the open maturity repo an ASF factor based on the counterparty as for the other kind of liabilities, thus 50% for non financial counterparties and 0% else, considering the open maturity repos are in the first bucket 0-6 months. An alternative is that articles 428l to 428o CRR are only valid for deals with a maturity and thus the ASF factor should be 0% whatever the type of counterparty.  About the reporting C 81.00, in the first case, the proposal is to report the open repo with other liabilities of the same counterparty type, thus potentially in section 2.3 for non-financial customers or section 2.5 for financial ones to keep coherence on the ASF factors. For the alternative, the open repos must be reported in 2.9.4 as specified in the ITS. 

  • 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: 2021_6328
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

CCF used for commitment performance bond

Which CCF must be applied to the undrawn/unissued amount if there is a commitment to a performance bond facility?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6327
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

C 14.00 - Column 0222: % of retail exposures in IRB pools

Is Column 0222 in C 14.00 (% of retail exposures in IRB pools) supposed to be reported for all securitisation positions?

  • 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: 2021_6324
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/06/2023

Real estate inspection for real estate valuation

What does the term 'valuer' mean? In particular, does it mean only a certified person? Will it be in line with the EBA guidelines if the inspection is done by non-certified assistants, sub-assistants, real estate agents, or even the real estate owner (owner takes pictures and sends to valuator)?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring
  • ID: 2021_6325
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/06/2022

C 24.00: Capital multipliers due to model limitations

Which is the correct way to report add-ons to the Own Funds Requirements in COREP C 24.00 (MKR IM) required by the regulator due to limitations of internal models?

  • 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: 2021_6323
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Approval to exclude IPS exposures from the Leverage Ratio exposure measure.

It is not clear from the instructions whether a specific approval from the competent authorities is necessary to exclude IPS exposures from the leverage ratio exposure measure or the approval referred to in article 113(7) of CRR is sufficient.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_6322
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2022

Authentication procedures that ASPSPs’ interfaces are required to support (using re-direction)

In a pure redirection-based approach, can an ASPSP, which is not offering a mobile web browser to its PSU’s, decide not to support  an authentication via a mobile web browser authentication page (no app-to-mobile web browser or mobile web browser-to-mobile web browser  redirection) for PISPs/AISPs on the basis of duly justified security risks, without being considered a breach of Article 97 (5) PSD2 and Article 30(2) of the RTS on SCA and CSC and/or an obstacle under Article 32(3) of the RTS on SCA and CSC?  

  • 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: 2021_6321
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 27/01/2023

PISP’s access to payable charges applied by the ASPSP on the PSU’s initiated payment via the ASPSP’s dedicated interface

Shall the account servicing payment service provider (ASPSP) make the transaction fees accessible to payment initiation service providers (PISPs) via the dedicated interface?

  • 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: 2021_6320
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

Disclosures Relating to Trading and Non-Trading Book Clients

When firms calculate exposure value in line with K-TCD, firms carry it out at client level, taking the replacement cost and PFE for each client and each product.  Firms then net exposures against collateral in line with Article 31 of IFR.   Assuming that an appropriate netting agreement is in place with the client, available collateral is deducted to arrive an exposure value for each client. Where clients have both trading book and non-trading book exposures, and the netting agreement in place provides that the collateral held is fungible i.e. there is no particular collateral assigned to the trading book or non-trading book contracts or transactions, for the above reporting schedules a methodology to apply the collateral between trading book and non-trading book exposures is required.  

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6319
  • Topic: Supervisory Reporting - IFR Reporting framework
  • Date of submission:

Future-dated payments and recurring transactions

When it comes to recurring transactions and future-dated payments, would an implementation of the PSD2-interface that requires that the TPPs store the payment details until due date, and not until due date are they allowed to send the transactions to the ASPSP for execution, satisfy the requirements in Opinion on the implementation of the RTS on SCA and SCA (EBA-Op-2018-04) of June 13, 2018' paragraph 29, in cases where the ASPSP itself offers future-dated payments and recurring transactions in their mobile/web-bank application? If the answer to the preceding question is yes, what then is the meaning of the statement '… a PISP has the right to initiate the same transactions that the ASPSP offers to its own PSUs, such as … recurring transactions, … and future-dated payments'?

  • 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: 2021_6318
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/10/2022

Amount of certain CET1 items available for stable funding

For the purposes of calculating available stable funding, it is unclear what amount should be reported, if any, as regards the following CET1 items: a) retained earnings, b) minority interests and c) amounts added back to CET1 due to the application of IFRS 9 transitional arrangements (Article 473a CRR).

  • 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: 2021_6317
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023