Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

FinRep Table 2: Interest income & Expense: Derivatives – Hedge accounting, interest rate risk

How should interest income & interest expense on derivatives (hedge accounting) be presented in Table 2 ? (i) Linked basis: Reported in Interest Income (row 070) if the derivative is hedging an asset item and Reported in Interest Expense (row 130) if the derivative is hedging a liablity item OR (ii) Gross basis: Hedge accounting derivatives resulting in Interest Income should be reported in row 070 and hedge accounting derivatives resulting in Interest Expense should be reported in row 130.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2284
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Application of the even deduction rule in case of intragroup transactions booked - by institutions which are parties to the contract - in different amounts

How to apply the even deduction rule stipulated in the Article 5(2) of the Commission Delegated Regulation (EU) 2015/63 and further clarified by the EBA Q&A 2015_1893 (Treatment of specific liabilities - even deduction) in cases where each party books the transaction in different amount?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_2283
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 05/08/2016

Completion of Annex I, Template C103.00 of the ITS needed?

For the high default portfolio benchmarking exercise we have noted that Annex I, Template C103 of the ITS is not included in the "DPM Table Layout and Data Point Categorisation 2.3.1.zip" for benchmarking on the EBA’s website: https://www.eba.europa.eu/-/eba-publishes-updated-dpm-and-xbrl-taxonomy-... Article 2(1)(c) of the “EBA Final Draft Regulatory Technical Standards on benchmarking portfolio assessment standards and assessment sharing procedures under Article 78 of Directive 2013/36/EU” refers to this template, but does not state that the template needs to be completed. Is completion of the Template C103 from Annex I required for the April 2016 benchmarking submission?

  • 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_2282
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification regarding the reference year for the purpose of the remuneration data to be collected by Competent authorities

The guidelines specify that data reported should relate to remuneration awarded to staff for the performance year preceding the year in which the information is submitted. To which amounts and year does the guideline refer exactly with regard to the collection of the fixed and variable component of remuneration?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/07 - Guidelines on data collection exercise regarding high earners
  • ID: 2015_2276
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/01/2016

Clarification regarding the reference year for the purpose of the remuneration data to be collected by competent authorities

The guidelines specify that data reported should comprise fixed and variable remuneration awarded for performance during the performance year preceding the year of submission of the information? To which amounts and year does the guideline refer exactly with regard to the collection of the fixed and variable component of remuneration?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/08 - Guidelines on remuneration benchmarking exercise
  • ID: 2015_2275
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/01/2016

Market, Credit and Counterparty risks of Central Counterparty under CRR

For Central Counterparty (CCP) acting under Regulation (EU) n°648/2012 (EMIR) with a banking license, - Should the risks already covered by specific financial resources as referred to in Articles 41 to 44 of EMIR be subject to capital requirements under Regulation (EU) n°575/2013? - Should the risks towards a CCP arising from an interoperability arrangement which fulfilled the requirements referred to in Articles 52 and 53 of EMIR and already covered with such requirements be subject to capital requirements under Regulation (EU) n°575/2013?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2274
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

F35.00 Covered Bonds - Solo Legal Entity Split

How should we report Solo Legal Entities cases, where assets are included in the covered bond pool, but the liabilities are held on another entity's balance sheet?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2015_2272
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F35.00 Covered Bonds - Maturity profile of covered assets

How should the maturity profile of the covered assets be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2015_2271
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F35.00 Covered Bonds - FX rates to be applied

There are circumstances where the covered bond has been issued in one currency and the underlying assets are in a different currency. In which case, the covered bond programme would hedge this cross currency risk. In this circumstance, which FX rate should be applied? The spot FX rate as per the reporting date or the strike FX rate as per the swap agreement?

  • 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_2270
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

F35.00 Covered Bonds reporting of over collaterization

In Rows 020 and 030, Columns 220-250, are UK banks required to complete these cells if over collateralisation is determined on a nominal basis as per UK covered bond regulations?  If so, how should over collateralization be translated into Present Value (what discount rate should be applied) or how should we determine the Asset Specific Value?

  • 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_2269
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Appropriate risk weight for speculative immovable property financing

Does CRR Article 128 (1) provide that a 150% risk weight need not be applied to one or more exposures listed in CRR Article 128 (2) - including speculative immovable property financing - or that are identified in accordance with CRR Article 128 (3), on the basis that it would not be appropriate to apply that rate to such an exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2268
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/10/2016

Treatment of derivative liabilities in the denominator of MREL

What does Article 45 (1) of Directive 2014/59/EU (BRRD) mean by including derivative liabilities in the total liabilities on the basis that full recognition is given to counterparty netting rights?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2266
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Differentiation between specialised lending and sme exposures within exposure class corporates

The exposure class 'corporates' is splitted into sme, specialised lending and other corporates. Where must an institution report specialised lending exposures, that are at the same time exposures to sme? The implemented sme definition only the annualised returns (< 50 mln. EUR). Specialised lending exposures are identified through the rating methodologies, that have been applied to determine a credit quality.

  • 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_2259
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Calculation of Default rate past 5 years and Loss rate past 5 years

If bank applies AIRB models to RWA calculation (according with the decision of the competent authority) for a period shorter than 5 years, what time series should be used for calculation of 5-year average values when calculating default rates and loss rates ?

  • 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_2257
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Reporting of different AIRB models in the same benchmarking class (portfolio) - credit risk

If one of the credit risk portfolios defined in the benchmarking exercise covers two different AIRB models, how it should be presented in the benchmarking templates?

  • 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_2256
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Break clauses in capital requirements and Residual maturity

In a swap contract with break clauses, basically with an enforceable option of early termination by one of the counterparties, which is the residual maturity to be considered for the application of the CVA capital charge in article 384 of CRR? The residual maturity of the original contract or the residual maturity for the break clause date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2252
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 09/12/2016

Cap on inflows

Does a credit institution benefit from a cap on inflows of 90% when the sum of its activities as referred to in Article 33(3) and its activities as referred to in Article 33(4) exceeds 80% of the total balance sheet?

  • 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: 2015_2236
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/05/2016

Leverage ratio - Add-on calculation for SFT transactions in Financial collateral simple method

In the example below, under Financial Collateral Simple Method would the add-on be the same as under Article 429e(2) of the CRR, that is 25, or should it be based on (1025 * 0.20) = 205 – 200 (1000 * 0.20), that is 5?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2234
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/02/2017

LRCalc – Reporting of SFT Exposures according to Article 429 (5) (d), 429 (8) and 429b (1) CRR

Please clarify regarding securities included in Repo transactions. As per the guidelines for Row010 in LRCALC table, ‘cash received or security that is provided to a counterparty via the aforesaid mentioned transactions and is retained on the balance sheet...’ are to be reported in other assets in Row190.From the above, as cash received or security provided on balance are to be reported in Row190, these are not reported in Row 010.[1] However, for purpose of cash receivable and cash payable netting, cash received which is reported in Row190 is included for the purpose of netting which is reported in Row 010. Is there no contradiction in guidelines?As an example if an institution has done a repo transaction of own security (on balance sheet) of value 1025 and receives a cash of 1000, in Row190, 2025 is to be reported.In Row010, for purpose of cash receivable and payable netting, cash received 1000 is included in netting.Is this not double reporting?[2] In Row 020, ADD-ON for SFT transactions is to be reported as per Article 429b (1).As securities which are included in repo transactions and which are on balance sheet, full value of security is reported in Row190 as other asset, whether ADD-ON is to be calculated and reported for such securities?

  • 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_2233
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 24/11/2017