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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

CIU Correlation Test

When applying the correlation test outlined in Article 350(2b) to a given CIU position in order to determine the appropriate capital treatment for position risk, may an institution adjust the historical prices of the CIU to reflect solely those price movements which relate to the position risk of that CIU?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3538
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Covered Bond issuance on template F35 Asset Encumbrance

Should retained bond nominals be included F35 of consolidated returns?

  • 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: 2017_3531
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Cash collateral posted in the Asset Encumbrance return F32.01

Where should cash collateral posted be treated in the Asset Encumbrance return F32.01?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3530
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Validation Rules v5014_m and v5015_m for FinRep nGAAP (v2.6)

The definition of EBA Validation rules v5014_m and v5015_m does not work for FinRep nGAAP because template F 04.06 is missing in the formulas. 

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2017_3527
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

C 17.01 – Total gross losses and loss adjustments (v6127_h and v6128_h)

In the new version of the ITS available on the EBA website which explains the functional requirements regarding the DPM 2.7, it's stated in the presentation of rows 010-880: ‘Institutions that calculate their own funds requirement according to BIA can report those losses for which the business line is not identified in rows 910-980 only.’In the definition of row 910, the ITS clearly states: ‘It may be higher, if an institution calculating its own funds requirements according to BIA cannot identify the business line(s) affected by the loss in every case. [...]'.This definition make sense for us, as it pastes with the requirement defined above mentioning that BIA losses may in certain cases only affect rows 910-980.But in the same case the definition of row 920-924 and the validation rules v6127_h and v6128_h seem to indicate that row 920 and 940 must be calculated as simple aggregation of the previous rows: ‘the gross loss amount (new events) reported in row 920 is the simple aggregation of the gross loss amounts of new events for each business line.’ Such indications for us are not consistent with the previous one indicating that for BIA only the total section may be fed.Please can you tell us in case of losses calculated under BIA with no business line attached how we should feed them in the C 17.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3522
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 24/11/2017

CET1 Instruments

May a CET1 instrument rank pari passu in liquidation with a legacy Tier 1 instrument that is being grandfathered as Additional Tier 1 under Article 484, and otherwise qualifies as Tier 2 under the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3521
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Exposures to regional governments, local authorities or public sector entities which are treated as exposures to central governments under Articles 115 and 116 CRR

Please clarify how Article 115(2) CRR shall be applied in case regional governments and local authorities are treated under the SA by application of Article 150 CRR and central governments are treated under the IRB Approach. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3517
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Inconsistency in validation rule v5016_s for C 05.01

Is validation rule v5016_s consistent for rows 130 and 136 of the C 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)
  • ID: 2017_3516
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Cap on the own funds requirement for a net position

Article 335 refers ‘The institution may cap the own funds requirement for specific risk of a net position in a debt instrument at the maximum possible default-risk related loss.....’. This article suggests that the Specific Risk requirement in column 060, rows 260 to 320 (column 060) of template C 18.00 should be the adjusted ‘capped own funds requirement’ and reduced to the maximum loss.However, the validation rules v0578_m and v0579_m require that column 060, rows 310 and 320 are the result of column 050 multiplied by 0.08 or 0.12. Of course, capping and adjusting the specific risk breaks these rules and prevents submission. Should the requirement itself be reduced or should the Net position in column 050 of the relevant rows be adjusted?

  • 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: 2017_3513
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/12/2017

Nominal value of collateral received - not available for encumbrance

Point 16 of Annex XVII on Asset Encumbrance reporting states that "Assets are non-available for encumbrance" when they have been received as collateral and the reporting institution is not permitted to sell or re-pledge the collateral, except in the case of a default by the owner of the collateral. We understand from the above that 1. we should only report in Column 070 of AE-COL template, the collateral received from our clients up to the amounts of their actual exposure on the reporting day. 2. Question arise on the rule to follow to report the collateral per issuers type/type of securities in column 70. Example: At reporting date: Client 1 has €1,000 cash and €2,000 securities (€500 Govies, €1000 Financial Corps, €500 Non Financial Corps) in its account with our company. Both the cash and securities accounts of client 1 are flagged as pledged in favour of our company in case of client1's default. Client 1 has entered into deals exposing our Company to €1,200 (Exposure in Basel III) In the books (off balance sheet) of the company, the collateral received will amounts to €3,000 In AE report AE COL column 70, base on point 16 of Annex XVII of ITS, we understand that we should not report €3,000 since our company could only sell the collateral up to the level of Client 1 exposure, ie €1,200 + relevant margins. If this this understanding is correct and €1,200 + relevant margins should be reported, question arises on the way we should select this amount amongst the total collateral received. The implemented selection will indeed impact the content of the reporting rows 150 to 230. We could indeed pick up €500 Govies, €500 Non Financial Corps and €200 cash or €1,000 Financial Corps and €200 Non Financial Corps), any other configuration

  • 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: 2017_3512
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Scope of the Covered Bond Exemption as set out in Article 30 of the Margin Rules.

Does the exemption in Article 30 of the Margin Rules concerning OTC derivatives concluded in connection with covered bonds apply where the conditions in Article 30.2 are satisfied in respect of all such covered bonds or only to those covered bonds that are issued by credit institutions that have their registered office in the European Union and which are subject to special public supervision designed to protect bond holders?

  • Legal act: Regulation (EU) No 648/2012 (EMIR) - only RTS 2016/2251
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2251 - RTS on risk mitigation techniques for OTC derivatives not cleared by a central counterparty (CCP)
  • ID: 2017_3511
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Treatment of expected loss amounts in validation rule v4772_m

Is validation rules v4772_m correct?

  • 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: 2017_3509
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/12/2017

Reporting of transfer between capital surplus (share premium) and retained earnings in FINREP F 46 template.

Under the Hungarian legislation negative balance of retained earnings could be offset by a transfer from other elements of own funds. If such transaction occurs how should it be reported in template F46?

  • 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: 2017_3504
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Incorrect validation rule - deposits guarantee scheme

We think that the validation rule v4134_m is incorrect.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2017_3502
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 04/12/2020

FINREP Template F20.04 (r210,r230)

Template F 20.04, row 210 reports ”Non-financial corporations – Of which: Loans collateralized by commercial immovable property”. However, in Hong Kong there could be non-financial corporations (NFC) borrowing loans that are collateralized solely by ”Residential immovable property” rather than by “Commercial immovable property”. For this case, should the corresponding loan amount be reported in row 230? Similarly, should household (HH) borrowing loans that are collateralized solely by ”Commercial immovable property” require to be reported in row 230, “Households – Of which: Loans collateralized by residential immovable property”?

  • 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: 2017_3486
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Question refer to Guidelines on disclosures requirments under Part Eight of Regulation No 575/2013 template 11 EU CR1-A Credit quality of exposures by exposure class and instrument

How to report data in Pillar 3 template 11: EU CR1-A Credit quality of exposures by exposure class and instrument?

  • 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: 2017_3481
  • Topic: Transparency and Pillar 3
  • Date of submission:

International Organisations allocated to the 'Institutions' exposure class

Could you please advise based on which criteria are International Organizations allocated to the “Institutions” exposure class under IRB Approach.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3479
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Reporting of revocable off-balance sheet commitments in FINREP IFRS9 template F 9.1.1

Where should the revocable off-balance sheet commitments be reported in FINREP IFRS9 template F 9.1.1? Annex V, Part 2, paragraph 103 requires that information on loan commitments, financial guarantees and other commitments given and received shall include both revocable and irrevocable commitments. Template F 9.1.1 includes three main categories: "off-balance sheet commitments and financial guarantees under IFRS 9 impairment”; “Other commitments measured under IAS 37 and financial guarantees measured under IFRS 4” and “Commitments and financial guarantees measured at fair value”. A revocable off-balance sheet commitment is not in scope of IFRS 9 Impairment, IFRS4, IAS37 (there is no contractual obligation which is a condition for IAS37) nor is it measured at fair value. Where should such a revocable off-balance sheet commitment be reported in template F 9.1.1? Does it have to be reported in F 9.1.1?

  • 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: 2017_3478
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of securitisation instruments in FINREP templates F 04.01 – F 04.04

How should Residential Mortgage-Backed Security (RMBS) instruments be reported in FINREP templates F 04.01 – F 04.04? Which counterparty sector should the RMBS be assigned to?

  • 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: 2017_3477
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Definition of "hybrid contracts" in FINREP template F 08.01

What shall be considered a ‘hybrid contract’ for the purposes of reporting FINREP template F 08.01?

  • 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)
  • ID: 2017_3476
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019