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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

Point in time when facility or limit is considered to be a commitment

Does a bank’s legally binding offer for a facility or limit constitute a commitment only after the client has accepted the bank’s offer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5836
  • Topic: Credit risk
  • Date of submission:

Treatment of committed facilities with unadvised limits

Are committed facilities with unadvised limits considered to be regulatory off-balance sheet items and do they have to be included in the conversion factor estimation under Advanced-IRBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5837
  • Topic: Credit risk
  • Date of submission:

treatment of uncommitted facilities / limits

Are uncommitted facilities or limits considered to be regulatory off-balance sheet items and do they have to be included in the conversion factor estimation under Advanced-IRBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5835
  • Topic: Credit risk
  • Date of submission:

Own funds instruments in template M 06.00

Please clarify how Own Funds shall be reported in template M 06.00.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5833
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Scope of Article 21a(6) CRD

What is the scope of application of the supervisory measures that can be imposed under Article 21a(6) CRD? Does it encompass for instance measures to address capital, large exposures, liquidity and internal model breaches?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5832
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 03/03/2023

FINREP template F44.03 Share based payments

In template 44.3 Staff expenses by type of benefits, in row 0020 Share based payments are requested. For the whole template the following validation rule applies: v3988_s: {F 44.03} >= 0 (for all rows and with severity level error). This is suggesting share based payments can never be a negative amount, which we believe is not always the case (as a result of changes in the fair value of the liability recognised). Can you please amend the Validation rule by excluding row 0020 from this rule?

  • 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_5831
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 26/11/2021

Reporting of residential mortgage loans on C80.00 - NSFR - Required Stable Funding

Can EBA confirm that a single residential mortgage loan with LTV > 80% should be split between rows 760 and 810 of the C80.00 based on the portion of the loan that a 35% risk weight would be applied to under the standardised approach to credit risk? The portion up to 80% LTV being reported in row 760 and the portion >80% LTV being reported in row 810. Can EBA also confirm that where mortgage loans are risk weighted using the internal ratings based approach, those loans are to be assigned to rows 760 and 810 as if standardised approach applied i.e. based on LTV ratio?

  • 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_5830
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 26/11/2021

Inclusion of central bank exposures in template C 33.00

Shall exposures to central banks be included in the COREP template C 33.00?

  • 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: 2021_5825
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Allocation of non-performing interdependent assets for NSFR purposes

How should non-performing interdependent assets be allocated in the NSFR template for required stable 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: 2021_5822
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Strong customer authentication (SCA) Knowledge element: Place of Birth and Date of Birth

Does a payer’s date of birth and place of birth constitute a valid Knowledge Element for strong customer authentication.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_5821
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 30/07/2021

Adjustments to RWA for DTA related to timing differences due to IFRS 9 transitional arrangements in template C5.01.

In template C05.01 validation rule v3689_s states that row010 column 040 cannot be negative. In our opinion, this is not true for RWA on DTA related to timing differences. EBA Q&A 2018_4189 does not include underpinning why the impact of IFRS9 transitional measures for RWA on DTA related to timing differences cannot be positive.

  • 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_5820
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Large Exposures Reporting - Reporting of Shadow Banking Positions under EBA Taxonomy 3.0

Institutions are required to report information on the 10 largest exposures to institutions on a consolidated basis, and on the 10 largest exposures to shadow banking entities that carry out banking activities outside the regulated framework on a consolidated basis, in accordance with Article 394(2) of Regulation (EU) No 575/2013. The reporting instructions for template C27.00, Column 070 state: The type of the counterparty of the ten largest exposures to institutions and the ten largest exposures to shadow banking entities shall be specified by using “I” for institutions or “S” for shadow banking entities, which carry out banking activities outside the regulated framework. We have reviewed the information in DPM database published on 8-Apr, together with the DPM dictionary and annotated templates published on 18th Mar and note that this states that only 'I' or 'U' can be used in this instance. There is no mention of 'S'. This being the case, please advise how Shadow Banking positions should be classified?

  • 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: 2021_5819
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 06/08/2021

Establishment and appointment of a CCP

Do the agents and distributors who are operating in a Member State (MS) or other MSs under the right of establishment based on Article 28 and 29 of PDS2 also fall under the scope of the Delegated Regulation (EU) 2018/1108 and are considered to be establishments (regardless of the way of the operation, distribution, e.g. tied agent or independent distributor, etc. ) under the AML regulation including the Delegated Regulation (EU) 2018/1108?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1108 - RTS on CCP to strengthen fight against financial crime
  • ID: 2021_5818
  • Topic: Central Contact Points (AML/CFT)
  • Date of submission:
  • Published as final Q&A: 17/03/2023

To overrule the validation error V09341_m in SBP credit risk report

Can you agree to overrule the validation error V09341_m in SBP credit risk reporting for context date of 202012?

  • 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: 2021_5817
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

To overrule the validation error V6205_m in SBP credit risk report

Can you agree to overrule the validation error V6205_m in SBP credit risk reporting for context date of 202012?

  • 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: 2021_5816
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Large Exposures : Mismatch between ITS and DPM v3.0 - C28 column 350 / C29 column 360.

The ITS states that a percentage of Tier 1 capital should be submitted for C28 column 350 / C29 column 360, whereas the DPM only permit a monetary 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: 2021_5814
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Gross carrying amount of held for trading financial assets in disclosure of non-performing and forborne exposures

Does the 'Carrying amount of Financial assets held for trading' include also the 'Gross carrying amount/nominal amount Performing exposure' in Template 3: Credit quality of performing and non-performing exposures by past due days, and also in the other related templates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/10 - Guidelines on disclosure of non-performing and forborne exposures
  • ID: 2021_5813
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Application of the leverage ratio exemption related to the passing-through of promotional loans to other credit institutions

Can the leverage ratio exemption related to the passing-through of promotional loans to other credit institutions (Article 429a(1)(e) CRR) be applied if an institution which is not a public development credit institution (Article 429a(2) CRR) but an entity set up by the central government, regional government or local authority of a Member State would issue promotional loans (Article 429a(3) CRR) through credit institutions and match these exposures by covered bonds on the liability side, under the same terms and conditions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5811
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/12/2021

CET1 available after meeting the entity’s requirements in case of a MPE approach

How should row 0400 ('CET1 (%) available after meeting the entity’s requirements') of Template M 02.00 of the ITS on disclosure and reporting on MREL and TLAC be filled in case of resolution groups with a multiple point of entry approach (MPE), where the resolution group is different from the prudential group?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2021_5810
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Transitional provisions under the IFR (Regulation 2019/2033)

How should the “twice the relevant own funds requirement pursuant to Chapter 1 of Title I of Part Three of Regulation (EU) No 575/2013”, referred to in article 57(3)(a) of Regulation 2019/2033 be understood?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5808
  • Topic: Prudential consolidation
  • Date of submission:
  • Published as Rejected Q&A: 25/04/2023