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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

Treatment of negative contribution base while calculating contributions to resolution financing arrangements

Due to specificities of the business model of some institutions, exclusions according to Article 5(1) of the Delegated Regulation (EU) 2015/63 may result in negative amount of total liabilities (excluding own funds) less covered deposits (contribution base according to Article 103(2) BRRD).Could you confirm that the approach in which the contribution base is floored to zero is correct in such cases?

  • 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: 2018_4002
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 15/11/2019

IFRS 9 Transitional arrangements – Calculation of the total exposure measure of the leverage ratio

According to Article 473a(7)(b) of CRR, is it correct to adjust the specific credit risk adjustments by applying a scaling factor for the only exposures subject to the standardised credit risk approach for the purpose of the calculation of the total exposure measure of the transitional leverage ratio?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2018_3995
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 15/02/2019

Validation rule v0682_m - DPM 2.7.0.1

Is the validation rule v0682_m correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3992
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/05/2019

FINREP Validation rule v5116_m

We wonder about the consistency of FINREP Validation rule v5116_m.v5116_m: [F 13.01] sum({F 13.01, r050, (c010-050)}) <= {F 05.01, r120, c060} - Value Inconsistency : F13.01 r050, (c010-050) = Maximum amount of the collateral or guarantee that can be considered for lending for house purchase; F 05.01, r120, c060 = Carrying amount for lending for house purchase - Scope of lending inconsistency : F13.01 r050, (c010-050) = only lending for house purchase with collateral or guarantee; F 05.01, r120, c060 = lending for house purchase with or without collateral or guarantee - Economic agents inconsistency : F13.01 r050, (c010-050) = all agents ; F 05.01, r120, c060 = Households

  • 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: 2018_3991
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Is the validation rule for Finrep (DPM 2.7) v5510_m, correct?

Is validation rule v5510_m correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3975
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Meaning of "the last three twelve-monthly observations" in Articles 315(1) and 317(4) CRR regarding the calculation of operational risk requirements

What is the correct application of the words “the last three”, which can be found in the wording “the last three twelve-monthly observations at the end of the financial year” in Article 315(1) CRR on BIA and in Article 317(4) CRR on STA? In particular, does “the last three” include the current year X when calculating the own funds requirements with reference date 31 December X?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3969
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 20/11/2020

Validation rule v6063_m in v2.7.0.1

Is validation rule v6063_m: [F 20.04] sum((F 20.04, r040, c010, (sNNN))) = sum((F 01.01, (r070, r093, r097, r110, r142, r172, r176), c010)) correct? Why are r235 and r390 (F01.01) not present in this validation rule?

  • 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: 2018_3963
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Double counting of intra-group funding in C68.00

"In C68.00 Unsecured wholesale funding (row 110) should be split per product type: - of which loans and deposits from financial customers (row 120) - of which loans and deposits from non-financial customers (row 130) - of which loans and deposits from intra-group entities (row 140) Should intragroup funding be reported exclusively in row 140? Or should it be reported in row 140 AND in row 120/130 depending if the intragroup entity is a financial or a non-financial customer? The same question applies to the split of wholesale funding."

  • 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: 2018_3962
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Scope of application of the secured lending regime for liquidity coverage requirement - non-financial customers

(i) Are loans secured by collaterals such as debt securities, equities, mortgages or movable property to be considered as secured lending pursuant to Article 28, paragraph 3 and Article 32, paragraph 3 and 4 of Delegated Regulation (EU) 2015/61? Those articles only refer to “secured lending […] transactions as defined in points 2 […] of Article 192 of Regulation (EU) N°575/2013” which defines “secured lending transactions” as “any transaction giving rise to an exposure secured by collateral which does not include a provision conferring upon the institution the right to receive margin at least daily”. (ii) What is the applicable inflow rate to monies due from those transactions, when those are provided to non-financial customers and when the collaterals provided are not reusable except in case of default of the borrower? Is it 100% as for secured lending transactions pursuant to Article 32 para. 3 (b) of delegated Regulation (EU) 2015/61 or 50% as for monies due from non-financial customers pursuant to Article 32 para. 3 (a) of the same Regulation?

  • 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: 2018_3959
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Compliance Function and Anti-Money Laundering tasks, Data Protection Officer or FATCA&CRS Responsible Officer, and Fraud Management

Is it in line with a) EBA/GL/2017/11 (Guidelines on internal governance) under Directive 2013/36/EU and b) with monitoring/advisory nature of the Compliance Function as a second line of defense, that the Compliance function in a Credit Institution is the main responsible for:establishing and maintaining compliance with anti-money laundering (AML) regulatory requirements?achieving and establishing compliance with personal data protection (GDPR) or FATCA&CRS (tax reporting) regulation?internal and external fraud prevention i.e. Fraud Management?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/05 - Guidelines on internal governance under CRD - repealing EBA/GL/2017/11
  • ID: 2018_3956
  • Topic: Internal governance
  • Date of submission:
  • Published as final Q&A: 18/01/2019

HQLA and amortised cost classification

If a bank holds HQLAs in the amortised cost portfolio and is able to monetise these assets can the securities, e.g. government bonds, in the amortised cost portfolio also be treated as HQLA in LCR calculation?

  • 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: 2018_3955
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Incorrect validation rule v4456_m

The validation rule v4456_m is not correctly defined in the taxonomy 2.7. Prerequisites are following: C 47.00 and C 43.00.a and C 43.00.b and C 43.00.c It means that all tables have to be reported. However a bank with a standardised approach to credit risk do not report table C 43.00.c. Consequently the rule can not be applied. In theory a bank can have no data for the table C 43.00.a as well.

  • 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: 2018_3950
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Look-through approach resulting in a credit risk position of own institution

When applying the look-through approach of Article 132(4) CRR, what risk weight shall an institution apply to a position that is based against its own institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3949
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

New risk weights for exposures to central governments or central banks not applicable in DPM 2.7 for C 07.00

How should the new risk weights be applied when they are not currently available in the DPM 2.7?

  • 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: 2018_3947
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/02/2019

Report gross or netted cash flows in the row 360 of C66 (maturity ladder) of non-forex and non-option-like derivatives under a valid netting agreement but without collateral agreement

« In the Annex XXIII (Maturity Ladder Instructions), for the row 360 ("1.5 Derivatives amount payables other than those reported in 1.4") , paragraph 2(b), it is stated that "flows related to other contracts than those referred to in point (a) shall be included by projecting the gross contractual flows of cash in the respective time buckets in lines 1.5 ‘derivatives cash- outflows’ and 2.4 ‘derivatives cash-inflows...’". Suppose that there is a group of derivatives (non-forex, non-option-like transactions) traded with the same counterparty under a valid bilateral netting agreement but without a collateral agreement in place, should netted cash flows per counterparty or gross cash flows be reported in row 360? If the netted cash flows should be reported in row 360, should the netted amount be calculated per day, or per time bucket defined for C66 report? For example, in C66, there is a time bucket 'Greater than 7 days up to 2 weeks', can we net an inflow of day 8 with an outflow of day 9 and then report only the net amount in row 360 (if negative) or row 670 (if positive)?”

  • 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: 2018_3943
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Pillar III templates aligned with the new supervisory reporting package, DPM 2.7

Should we adjust template EU CR2-A in order to facilitate the implementation of the EBA Guidelines on disclosure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2018_3941
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Meaning of current year in validation rule v6167_m

What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2018_3934
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019