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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

FINREP Template 25.01 FX results and vintage buckets

In template F25.01 Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E): Inflows and outflows is requested. How do we report FX differences for the period and especially for the vintage buckets (columns 0050-0100)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2020_5456
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Synthetic securitisatios

Can ‘vendor financing’ constitute a synthetic securitisation?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5454
  • Topic: Provisions applicable to all securitisations
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Credit faclity level

Is it possible to assign default according to the purpose of the loan (e.g only the exposure that was granted for renovation) and treat it as at facility level or not? In case of one agreement for 2 purposes and 2 amounts granted, from the regulatory perspective can we treat such approach as default assignment at facility level or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2020_5447
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Institution responsible for compliance with the requirements on a consolidated basis in a horizontally consolidated group

According to which provision of the CRR/CRD an institution shall be determined to comply with the requirements on a consolidated basis and to fulfil all requirements on the basis of the consolidated situation? Can Articles 18(3) and 18(6) CRR determine which institution in a horizontally consolidated group shall be responsible for compliance on a consolidated basis and for fulfilment of all requirements on the basis of the consolidated situation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5444
  • Topic: Other issues
  • Date of submission:

COREP C17.01 - Consistency of the EBA Taxonomy control v5839_m

Does the Control v5839_m take into consideration the possibility to report a correlated incident?

  • 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: 2020_5434
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Treatment of deducted exposures in the calculation of memo items “Risk-weighted exposure amount under SEC-ERBA” and “Risk-weighted exposure amount under SEC-SA” ({C14.01 c447} and {C14.01 c448} respectively)

How to treat deducted exposures in the calculation of the mentioned memo items, to allow for a coherent and homogeneous comparison between the own funds required by the different methods?

  • 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: 2020_5422
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Sign convention for “Credit risk adjustments during the current period” {C14.00 c225} and definition of "current period".

The sign convention that should be followed to report credit risk adjustments in column 225 of C14.00 is not clear. In the same way, the “current period” should be further specified.

  • 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: 2020_5421
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Weighting of EVE gains of domestic currency by a factor of 50% when calculating the aggregate EVE change for each interest rate shock scenario

When calculating the aggregate EVE change for each interest rate shock scenario, should EVE gains of the domestic currency (i.e. EUR in most cases) be weighted by a factor of 50% or should such gains be weighted by a factor of 100%?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/08 - Guidelines on the management of interest rate risk arising from non-trading activities
  • ID: 2020_5419
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Resolution planning for an established subsidiary part of a cross-border group with no Resolution College established

Please specify how the tasks referred in Article 88(1) of the Directive 2014/59/EU (BRRD) should be carried out in practice in case the group-level resolution authority has not set up a Resolution College? Should the resolution authority prepare and maintain resolution plan on an individual basis in respect of a subsidiary failing under its jurisdiction, which is part of a cross-border group, in case the Resolution College for the group has not been set up yet?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5403
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as Rejected Q&A: 16/12/2022

EBA validation rule v7365_m

Is v7365_m stating that for the C14.00 if ({c040} = [eba_RT:x10] or {c040} = [eba_RT:x11]) then {c140} <= {c130} 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: 2020_5402
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Credit risk framework applicable to investments in repack Notes issued by SPEs

What is the applicable credit risk framework in the non-trading book applicable to investments in repack Notes issued by Special Purpose Entities (SPEs)? How should an institution calculate the risk weight of an investment in a Repack Note if it does not consolidate the SPE but is able to look through to the underlying assets at all times?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5400
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

FINREP Payment services Template 22.2

The definition of Payment services has been updated in the FINREP DPM 2.9.2. Can the information asked in template 22.2 row 120 Payment services be removed?

  • 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: 2020_5399
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Mapping to exposure classes

Are Greenland, Faroer, Guernsey, Isle of Man and Jersey to be treated as "central goverments" under Article 112(a) CRR or are they to be treated as "regional governments" under Article 112(b) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5392
  • Topic: Credit risk
  • Date of submission:

Obligor level

When applying the default at obligor level for retail, should a credit institution always consider a specific set of individual obligors that have a joint obligation towards an institution as a different obligor (the unit of default takes into consideration the JCO)? Or is this to be applied only for the materiality threshold?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2020_5380
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/07/2021

Weighted average of the CCF

Internal authorized EAD models may calculate the EAD by means of several parameters, since the exposure behavior could be explained by different factors. Considering that this type of EAD internal model does not estimate a unique CCF, but rather several factors that are applied to different exposure components, the consequent approach implemented to report the CCF in Template C.101 ,C102 and C.103 has been the following: include in the field as per C.100 in Annex IV the parameter that, in the internal EAD formula, is applied to the undrawn amount, in line with the weights that shall be used to compute the average of the CCF at counterparty/portfolio level, according to the provision reported in Annex IV which make reference to art. 166, par 8 of CRR. Please confirm that this approach is in line with the provision set in ITS as for Annex IV C.100.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2020_5368
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 27/11/2020

SCA requirements with dynamic linking for mobile initiated credit transfers (MSCTs)

Can mobile initiated credit transfers (MSCT) solutions whereby a proximity technology (e.g. NFC, QR-code, BLE, etc.) is used for the exchange of payer identification data between the payer’s mobile device and the payee’s payment terminal but a mobile network is used (e.g. by a dedicated app) on the payer’s mobile device for the payer authentication, be considered as a proximity payment whereby strong customer authentication (SCA) may apply without requiring dynamic linking?

  • 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: 2020_5367
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 13/04/2022

Clarification on where the creation of the authentication code with dynamic linking for strong customer authentication (SCA) for electronic remote payment needs to be done

Should the authentication code be computed and dynamically linked to the transaction data in a unique processing step prior or together with the payer’s authentication on the payer’s device, or can the authentication code be computed and dynamically linked in one or several subsequent steps in the payment process, possibly not on the payer’s device?

  • 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: 2020_5366
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 30/07/2021

Clarification on the determination of the relevant currencies

1. How should CSD-banking service providers determine the negative net cumulative positions, which are needed to determine the relevant currencies as referred to in point (c) of Article 59(4) of Regulation 909/2014? 2. In addition, which values should be used to rank the currencies from highest to lowest? 3. Finally, how should the average for currencies without three negative net cumulative positions be calculated?

  • 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: 2020_5364
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 04/08/2022

Record Retention - Struck Off Obliged Entities

Who is responsible to retain the records referred to in Article 40 of Directive (EU) 2015/849 once an obliged entity goes into liquidation and eventually ceases to exist?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5362
  • Topic: Other topics
  • Date of submission:

Contingent encumbrance

For Scenario A of Contingent Encumbrance reporting template F34.00, should the 30% decrease in value be assumed for the instrument that is encumbered, or should it be considered whether such an instrument itself has underlying values for which the 30% decrease in value should be assumed?

  • 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: 2020_5359
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 19/03/2021