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List of Q&A's

Financial Guarantees in templates Z 05.02 / T 12.00

Annex II states that "Major off-balance sheet counterparties shall be identified by summing up the total nominal amount of commitments and financial guarantees received (as defined for the purposes of FINREP, template F 09) by the entity or group entities for which the template is reported from counterparties or group of connected clients".  With regard to financial guarantees received, do all the financial guarantees received where the Institution is the beneficiary of the guarantee (thus including the guarantees that cover bank's assets and not liabilities) have to be reported in template F 09.02? Or should for templates Z 05.02 / T 12.00, only the financial guarantees where the reporting Credit Institution is the counterparty guaranteed (thus covering its liabilities) be considered or, as for F 09.02, also the financial guarantees received where the reporting Credit Institution is the beneficiary (thus covering its assets)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2021_6109
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Reporting of items deducted from T1 in RWA columns in C43 (Breakdown of LR Measure)

It is not clear from the instructions whether items deducted from T1 should be included in the columns dedicated to RWAs in C43.

  • 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_6106
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Dutch Residential Real Estate Mortgages - covered by NHG - Nationale Hypotheek Garantie - National Mortgage Guarantee - Calculation of RWA within and outside the Netherlands

If a foreign bank, with a Dutch branch, is exempt from applying the rules from the Dutch NCA for the branch, would this not lead unfair competitive advantage?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6105
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Clause of substitution of investor or remarketing for capital or internal MREL

In the context of a bond issued by a subsidiary to the parent company recognized as Own Funds or Eligible Liability, would it be possible to insert a clause of change of control that would allow the parent company, if it is no longer the owner of the subsidiary, to automatically sell the bond to the purchaser of the subsidiary?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6104
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 07/09/2022

Assets encumbered for a residual maturity of one year or more in a cover pool funded by Covered bonds for NSFR purposes

Does the 85 % required stable funding factor apply to assets encumbered for a residual maturity of one year or more in a cover pool funded by Covered bonds issued directly in the market, as well as to the assets underlying self-issued Covered bonds used as collateral for long term ECB funding or SFT with the market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6096
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Regular-way purchases under trading date accounting and settlement date accounting

[1] There are guidelines available in C47 for reporting Regular-way purchases under trading date accounting and settlement date accounting. There are no guidelines in C43 or C40 for reporting the same. [2] The cash receivable and cash payable a as reported in C47,  in which rows of C40 and C43 under other assets out of these positions are to be reported? [3]As these assets of cash receivables are also reported as other assets in Row0190 are these not  duplicated in C47?

  • 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_6095
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Cash pool assets in C 47.00

As per ITS of C47, Cash pool assets are to be reported in C47 Rows 0193 to 0198. [1] As net amount of cash pool asset for the group entity are likely to reported in Row 0190, of C47 as other assets. Is it not double counted to the extent of amount reported in Row0190 with regard cash pool assets? [2] As there is validation (v4456) between C47 Rows 0010 to 0290 = C43 total assets, where are these cash pool assets as reported in C47 are to be reported in C43? [3] Whether Cash pool assets as reported in C47 are also to be reported including positive and negative amounts. [4] Is the scope of prudential netting mentioned under article 429b, applicable only for Leverage ratio or does this prudential netting has some thing to do with prudential report applications like COREP?   

  • 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_6094
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Securities lent under sale accounting

As per ITS, in line with article 429e (6) of CRR2, The value of securities lent in a repurchase transaction that are derecognised due to a sales accounting transaction under the applicable accounting framework are to be reported  Row 230 of C47. [1] For such repurchase transactions under sale accounting, cash received part is to be allocated in Row 0190 of C47? So also in C43 and C40 the same rule applies? In 47, Row 010, securities under sale accounting are not to be reported as they are expected in Row 230 of C47. [2] The same rules apply to C48 with regard to columns of rows in C47 0010 to 0050, which are to be reported in C48.02 in line with ITS. The validation rule v10094_m expects Row0010 |Col0020 >= Row0010|Col0030 Is this possible as only reverse repo leg and add-on are expected in Col0020 are to be higher or equal to the value of  securities lent under sale accounting are to be reported in Col0030?  [3] As per EBA guidelines, where the institution adopts sale accounting of repo, they should reverse such transactions and report in COREP reports including Leverage ratio. It means, except for the change for securities under sale accounting are to reported in Row 230, while the institution which does not adopt sale accounting are to report own securities under Row0190. Except for this change, add-on and other calculations are same. Please confirm. 

  • 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_6093
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Calculation of own funds requirements for operational risk under BIA

Under the Basic Indicator Approach used to calculate own funds requirements for operational risk, how should the interest revenues from impaired loans be considered in the calculation of the Relevant Indicator (RI), namely, on the gross carrying amount of the loans or on the net amount i.e. after the deduction of the result on specific provisions or impairment losses for interest on impaired loans?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6092
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 21/12/2022

Validation rules v6423_m, v7267_s, v7268_s, v7270_s, v7271_s, v7272_s, v7273_s and v7275_s

How to deal with negative sums in validation rules v6423_m, v7267_s, v7268_s, v7270_s, v7271_s, v7272_s, v7273_s and v7275_s?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2021_6091
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 29/03/2023

Resolution planning reporting (RES), validation rule v09343_a

How should validation rule v09343_a be used?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2021_6090
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 22/02/2023

Intermediate Parent Undertaking

Which authority is competent for allowing institutions to have two IPUs under Article 21b(2) CRD?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6088
  • Topic: Other issues
  • Date of submission:

Residual contractual maturity date applicable to commercial paper issued under a commercial paper program with a firm underwriting commitment to rollover

What should be the residual contractual maturity applicable to commercial paper issued under a commercial paper program with a firm underwriting commitment to rollover?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6087
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 22/12/2022

ASF applicable to payables (accruals) in the NSFR

What should be the available stable funding factor applicable to payables (accruals)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6085
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Capacity of a CSD-banking service provider to convert into cash on a same-day basis collateral or investments through prearranged and highly reliable funding arrangements

What is the meaning of “same day basis” and the settlement period linked to it in Article 10(2)(f) of Regulation (EU) 2017/390?   Furthermore, in view of cut-off times of prearranged and highly reliable funding arrangements including committed repo lines, does the notion ‘same-day basis’ strictly require the conversion of collateral or investments into cash on the same day, or is it sufficient that a CSD-banking service provider has the capacity to start the conversion process on the same day?

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2021_6083
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 06/01/2023

Definition of parent undertaking for the purposes of CRR

Can an undertaking for which Directive 2013/34/EU (the “Accounting Directive”) does not apply be considered a parent undertaking for the purposes of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6082
  • Topic: Own funds
  • Date of submission:

Deduction of software assets from Common Equity Tier 1 capital (hereinafter CET1) for investment firms of Class 2 and Class 3

Is it appropriate to apply Article 13a of Commission Delegated Regulation (EU) No 241/2014, amended by Commission Delegated Regulation (EU) 2020/2176, regarding the deduction of software assets from CET1 to investment firms of Class 2 and Class 3, taking into account that the mentioned investment firms are not subject to the application of provisions established in Art. 113(5) and Art. 156 of the CRR, i.e. to apply 100% of risk weight to the portion of the carrying amount of software that is not deducted from CET1?

  • 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
  • ID: 2021_6079
  • Topic: Own funds
  • Date of submission:

Information on the host member State in which Third Party Providers (TPPs) provide services

If a payment institution, in the specific form present in the EBA register under PSD2, presents an EU passport, does this mean that the Third Party Provider (TPP) is authorised to operate for the services indicated in all EU countries?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2019/411 - RTS on EBA register under PSD2
  • ID: 2021_6078
  • Topic: Central register of the EBA
  • Date of submission:
  • Published as final Q&A: 14/10/2022