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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

Inclusion of interim profits in CET1

After the competent authority (CA) granted a permission to include interim profits in CET1 on the basis of the Article 26(2) CRR, on what date do these interim profits become part of CET1 capital?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions

Inclusion of interim profits in CET1

Could interim profits, which are not profits from the recent reporting period but from the previous one, be included in CET1 capital before the institution has taken a formal decision confirming the final profit or loss of the institution for the year on the basis of Article 26(2) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions

Follow-up to Q&A 2016_2609 - Template C 71.00

With reference to 2016_2609, please can you confirm whether the predominant currency in the rest of line means a) the predominant currency in the rest of the line provided by the counterparty providing the multi-currency facility or b) the predominant currency in the rest of the line provided by all counterparties?

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or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Deferral of variable remuneration in instruments

Does a credit institution have the obligation to hold the instruments (as shares, for example) during the deferral period of variable remuneration in instruments?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)

Finrep. Validation rule v5443_m and others

Our opinion is that rule v5443_m has been wrongly implemented by the EBA. The formula is the following : {F 18.00.a, r100, c010} = sum({F 04.09, r100, (c010, c020)}) + sum({F 04.10, r150, (c010, c020)}) - sum({F 04.10, r150, (c015, c025)}) + {F 01.01, r030, c010} This rule seems to be designed for nGAAP reporters as in its formula there are some explicit references to F 04.09 and F 04.10 templates which are nGAAP reporters templates. The problem is the following : The last data point on the right hand side of v5443_m shall be in my humble opinion F 01.01, r040 and not F 01.01, r030. In the current implementation, the EBA is comparing loans and advance to credit institutions (F 18.00 row 100, col 010) with cash balances at central banks which does not make sense. v2776_m which is the same rule but this time designed for IFRS reporters seems to be correct as the last data point on the right hand side of the formula refers this time to row 040 : {F 18.00.a, r100, c010} = sum({F 04.04.1, r100, (c015, c030, c040)}) + {F 01.01, r040, c010} Could you please confirm that rule v5443_m has been wrongly implemented by the EBA?

  • 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)

Scope of application of the term "securitisation" and risk retention obligation in Article 405 CRR

Does the term ‘securitisation’ defined in Article 4(1)(61) of Regulation (EU) No 575/2013 capture loan origination, as opposed to loan acquisition, where the loan origination occurs over a defined period and is subject to the originated loans satisfying specified eligibility criteria, and is funded by the originator issuing tranched debt with the subordination of the tranches determining the distribution of losses during the ongoing life of the portfolio of originated loans?

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

Template FinRep F01.03 Balance sheet Statement - Equity

In annex IV the line 030 "Unpaid capital which has been called up" of Template F01.03 has its reference IFRS in "black" as if this line has not to be remitted in IFRS Standard. In Annex III this line is also in black in column reference but the line is present in the Template (that i call drawn on the Template). It is the only cell drawn in black in templates full IFRS present in Annex III, and no comment explain what it means. Other lines with NGAAP BAD references are not present in the templates (for example lines 201 to 209 of the same Template F01.03 are not drawn). When we remit this Template on XBRL remittance gate ONEGATE of ACPR this cell is gray and is not required. But is it the choice of French NCA. Do the NCAs have choice to ask this line or not ? Have the establishments the choice ? Is it an error in Template IFRS, in fact this line has not to be present ?

  • 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)

Treatment of undrawn committed facilities backed by own issuances.

Should the undrawn committed facility in the form of LTRO2 backed by own issuances be reported in the line 3.8 (Undrawn committed facilities received) of the C66 model?

  • 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)

Contextual limits to the ancillary power in Article 64.1.f) BRRD

Should the power in Article 64.1.f) BRRD be interpreted as limited by the context of the specific resolution tool used in the particular case?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Presentation of cash flows related to non performing exposures in the template (C 66.01.a)

It is not clear how to interpret the following instruction: “17. Past due items and items for which the institution has a reason to expect non- performance shall not be 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)

Clarification “Other collateralized loans” template F 05.01

Should “Finance leases” and “Reverse repurchase loans” be excluded from the specification in row 100: “of which: other collateralized loans” in template F 05.01?

  • 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 rules on template F 18.00 comparing with F 04.04.1 and F 01.01

In the validation rules v2776_m the balance from F01.01 row 040 Other demand deposits is added. In the validation rules v3028_m/v3031_m/v3035_m row 040 Other demand deposits is not added. In these validation rules the Impaired amounts in template F 18.00a are compared to the Stage 3 amounts in template F 04.04.1 (excluding 040 other demand deposits). Is this correct?

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

Validation rule v3129_m (FINREP template 18 and 19 IFRS 9)

The validation rule v3129_m requires for template 19 FINREP for all rows (010;020;030;040;050;060;070;080;090;100;110;120;130;140;150;160;170;180;181;182;183;184;185;186;191;192;193;194;195;196;197;201;211;212;213;214;215;216;221;222;223;224;225;226;227;231;330) that column {F 19.00.a, c100 of which: Impaired (Non-performing (Forborne)} <= {F 18.00.a, c120 of which impaired (non performing). For most rows this validation rule is correct. But for the rows (211;212;213;214;215;216;221;222;223;224;225;226;227;231) the column 100 in template 19 and the column 120 in template 18 are both greyed out. Can you limit the validation rule v3129_m to the rows (010;020;030;040;050;060;070;080;090;100;110;120;130;140;150;160;170;180;181;182;183;184;185;186;191;192;193;194;195;196;197;201;330)?

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

Validation rule v2707_m (FINREP template 18 IFRS 9)

The validation rule v2707_m requires for template 18 FINREP for all rows (010;020;030;040;050;060;070;080;090;100;110;120;130;140;150;160;170;180;181;182;183;184;185;186;191;192;193;194;195;196;197;201;211;212;213;214;215;216;221;222;223;224;225;226;227;231;330) that column c120 of which impaired should be <= c060 Total non-performing. For most rows this validation rule is correct. But for the rows (211;212;213;214;215;216;221;222;223;224;225;226;227;231) the column 120 is greyed out. Can you limit the validation rule v2707_m to the rows (010;020;030;040;050;060;070;080;090;100;110;120;130;140;150;160;170;180;181;182;183;184;185;186;191;192;193;194;195;196;197;201;330)?

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

Applicable treatment of fair value changes for the identification of the applicable RW to exposures in default under the Standardised Approach

In the application of Article 127 CRR, should the credit risk adjustments embedded in the fair value be considered in the calculation of the percentage of the unsecured part of the exposure value represented by credit risk adjustments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments

Recalculation of thresholds of Article 48 CRR due to IFRS 9 transitional arrangements (Art. 473a)

Do the thresholds of Article 48 of Regulation (EU) No 575/2013 (CRR) have to be recalculated in the context of Article 473a(7) as well, taking into account the amounts added back to CET1 due to the application of Article 473a?

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

Calculation of the sf factor as per Article 473a(7)(b) of Regulation (EU) No 575/2013 (CRR)

Please clarify whether "RAsa" which is used for the calculation of the “sf” factor, as per Article 473a(7)(b) of the CRR, should be gross or net of tax

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

Computing the amounts mentioned in Article 473a(2)(b) CRR, in case of the credit-impaired financial assets measured at amortised cost.

Should the amounts mentioned in Article 473a(2)(b) of Regulation (EU) No 575/2013 (CRR), as modified by Regulation (EU) No2017/2395 be:the total IFRS 9 Expected Credit Loss at transition date - point (i) and the amount of IAS 39 impairment losses at the day before transition date – point (ii), in case where there’s no modification regarding the reporting of the credit-impaired financial assets’ gross carrying amount (IFRS 9 vs IAS 39);the total adjusted IFRS 9 Expected Credit Loss at transition date - point (i) - see details below - and the amount of IAS 39 impairment losses at the day before transition date – point (ii)or the total IFRS 9 Expected Credit Loss at transition date - point (i) and the adjusted amount of IAS 39 impairment losses at the day before transition date – point (ii) – see details below, in case where the reporting of the credit-impaired financial assets’ gross carrying amount is modified (IFRS 9 vs IAS 39).

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

Reporting of own funds deductions required by the competent authority.

What is the treatment for the purpose of supervisory reporting of specific own funds deductions or prudential filters required by the competent authority pursuant to Article 104(1)(d) of Directive 2013/36/EU?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/13 - Guidelines on common procedures and methodologies for the SREP

C 08.01 - validation rule v5739_h (applicable as of v2.7)

According to validation rule v5739_h, the value in row 010 (“Total exposures”) should be >= the value in row 015 (“Exposures subject to SME-supporting factor”). We think this rule is only relevant for columns which report amounts and not for columns which report averages, such as column 250 (exposure-weighted average maturity value). Can this validation rule be corrected and not be applied to column 250 anymore?

  • 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)