Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Sign Convention

Column 030 in C 07.00 (-) VALUE ADJUSTMENTS AND PROVISIONS ASSOCIATED WITH THE ORIGINAL EXPOSURE) has negative sign, while in C 09.01 columns 050to 070 has (+) sign convention. We would like to know that what is the rationale behind having different sign convention for same fact?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2014_1625
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

HANDLING OF CASH COLLATERAL DEPOSIT HELD WITH OUR BANK

Bank A is solo reporter and is a small subsidiary bank owned by foreign Government of (Third) country X (51%) and Bank A (49%). In the General ledger it has a loan to a Public Sector Enterprise incorporated in the (Third) country X. This loan is backed by cash collateral provided to Bank A by the Central Bank of the (Third) Country X which covers the outstanding balance (principal) on the loan fully - only the interest remains uncovered.How shall this loan and the linked deposit be reported for liquidity purposes in the LCR templates (C 52.00 / C 53.00)?Operationally, the deposit is expected not to generate any additional liquidity buffer requirement as the deposit is expected to be returned only when the loan is fully paid, thus covering the expected outflows by the inflows.

  • 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: 2014_1624
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

FINREP

According to the Financial Conduct Authority in the United Kingdom, only groups that report under International Financial Reporting Standards (IFRS) are subject to FINREP. However, the EBA has issued templates and instructions for groups that report under National GAAP. Therefore the EBA is indicating that groups must submit FINREP reports regardless of whether they report under IFRS or National GAAP. Please advise if groups reporting under National GAAP are required to provide FINREP submissions.

  • 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: 2014_1621
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Applicability of Article 423(1) of the CRR for intermediaries facilitating derivatives clearing between its clients and a CCP

Is it permissible for an institution, for which the following is true, not to apply the additional outflow required under Article 423(1) of Regulation (EU) No 575/2013 (CRR): (i) the institution acts as a financial intermediary in the meaning of Article 303 of the CRR between a client and a central counterparty (CCP) in order to facilitate the central clearing of the clients’ derivatives (as e.g. required in the future by Regulation (EU) no 648/2012 (“EMIR”)); and (ii) it is contractually assured that the institution immediately receives collateral from its clients in case the value of the collateral posted to the institution as margin for its set of derivatives channelled through this intermediary to the CCP is not sufficient to cover the CCP’s margin requests for the set of derivatives.

  • 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: 2014_1619
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 10/07/2015

Definition of financial corporates for Leverage Ratio and FinRepITS

Is the definition of financial corporates really different in the Leverage Ratio and FinRep ITS?

  • 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: 2014_1618
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Specialised Lending Supervisory Slotting Method and CRM Substitution Approach

1) Can the CRM substitution method be used for specialised lending exposures when the supervisory slotting method is applied under the CRR?2) If this answer is yes, can we request that the relevant cells in template C8.01a (i.e. columns 70 and 80) are opened for rows 90-150 to allow banks to report this information correctly?

  • 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: 2014_1604
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Treatment of cash at bank under the large exposures regime

According to EBA Question ID 2013_412, "cash" positions do not fall under the scope of the large exposures regime and do not need to be reported.1)      Could you please confirm whether cash at bank deposited by an investment firm fall under the large exposures regime?2)      Could you please also provide us with the relevant reference in the CRR which states that cash positions are excluded from the large exposures regime?3)      When you are referring to "cash" positions do you include both cash held at hand and at bank?If indeed cash deposits are considered in the calculation of large exposures, where these should be reported in the C 28.00 and C 29.00 templates?

  • 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: 2014_1598
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Directorships

What is the correct interpretation of Article 91 (4) b) ii) of CRD IV setting the rules for quantifying executive and non-executive directorships within undertakings in which the significant institution holds a qualifying holding? i. An individual holding directorships in four undertakings in which the significant institution holds a qualifying holding will be treated as one single directorship with the directorship held within the significant institution being treated as a separate directorship. ii. An individual holding directorships in four undertakings in which the significant institution holds a qualifying holding with the directorship held within the significant institution not being treated as a separate directorship.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1595
  • Topic: Internal governance
  • Date of submission:
  • Published as final Q&A: 13/11/2015

Exemptions from the application of Article 395(1)

Could exposures of an institution fully guaranteed by its parent undertaking - considering the substitution approach under Article 403(1)(a) of Regulation (EU) No 575/2013 (CRR) – be exempted from the large exposures provisions and in this way from the application of Article 395(1)? Furthermore, may the guarantees provided by the parent institutions from another Member State be handled in Article 403 of the CRR as a third party guarantee?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1592
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 10/07/2015

Aggregate Liabilities

Where wholesale funding issuance is undertaken in a currency which is different to the base reporting currency of the institution, and on issuance is swapped back for the duration of the liability (therefore leaving the institution with no currency risk on the transaction), does this issuance count towards the aggregate liabilities cap for single currency reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1579
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/02/2015

LCR Inflows: current accounts with other credit institutions

Article 425(2)(c) of Regulation (EU) No 575/2013 (CRR) specifies that assets with an undefined contractual end date shall be taken into account with a 20% inflow provided that the contract allows the institution to withdraw and request payment within 30 days. Do current accounts held with other credit institutions fall into that category? If not, how should these current accounts be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1576
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/02/2015

Basis of reporting value - C 04.00 row 840 - Own funds based on Fixed Overheads

Please clarify the basis for reporting this number should it be on the basis of a risk weighted exposure or an own funds requirement.exposure at 8%

  • 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: 2014_1574
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Interaction of Article 227 of the CRR (0% volatility adjustment under FCCM) and Article 401(3) (stress test of realisable value of collateral)

Our question concerns the application of Article 227 of the CRR (0% volatility adjustment under FCCM) and the interaction with the collateral stress test described in Article 401(3). The latter requires collateral values to be stressed, and the impact on Article 395(1) to be determined. It follows that the own funds requirement for large exposures in the trading book (calculated under Article 397 of the CRR) is adjusted upwards to take account of the stressed collateral values. Where the criteria set out in Article 227 of the CRR are met and 0% volatility adjustment is applied to repo/reverse repo transactions, is this exposure value taken as the base case for comparison with the stressed collateral impact calculated under Article 401(3)? Or are these two articles to be read in the reverse order, such that 0% volatility haircuts per Article 227 are also applied in the collateral stress test (Article 401(3))?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1573
  • Topic: Large exposures
  • Date of submission:

Reporting of template C017.00

According to ITS Annex II, Part 2, paragraph 119. C017.00 The template C017.00 summarises the information by an institution in the last year. According to EBA final Q&A 2013 285: The reporting of C 17.00 (OPR Details) shall be based on the calendar year. The figures reported in June of the respective year are interim figures, the final figures are reported in December. But it is still not clear whether data is expected on the relevant calendar year (as current year) or on the last calendar year (as previous year): 1) data as of June 30, 2015 is about gross losses relevant to last calendar Year 2014 (the whole year) or about gross losses relevant to current calendar Year 2015 (1. half-year)? 2) data as of December 31, 2015 is about gross losses relevant to last calendar Year 2014 or about gross losses relevant to current calendar Year 2015?

  • 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: 2014_1571
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

AE: F3201, F3202, F3203 - Discrepancy between taxonomy and ITS

In ITS , some cells are shaded according to whether it’s a consolidated or individual template. Now, in the DPM as in taxonomy, these conso/individual characteristics do not seem to be taken into account. The remark concerns the following columns: F3201 : C020 and C070 F3202 : C020 and C050 F3203 : C020

  • 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: 2014_1569
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/06/2021

Definition of the term „applicable amount“ with regard to the determination of the deductions from common Equity Tier 1 items of holdings by the institution of instruments of financial sector entities where the institution has a significant investment in those entities in Article 36(1)(i)) CRR

What is the relevant definition of the „applicable amount” in Article 36(1)(i) of Regulation (EU) No 575/2013 (CRR) with regard to the determination of the deductions of holdings by the institution of the Common Equity Tier 1 instruments of financial sector entities where the institution has a significant investment in those entities and for those entities the institution used the equity method under Regulation (EC) No 1606/2002 on a consolidated basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1568
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Risk-weighting of Pension Assets

Article 36 of the CRR requires that defined benefit pension fund surpluses be deducted from CET1 - unless the bank has unrestricted access to the surplus and has obtained permission from the competent authority, as Article 41 sets out further. Any such accessible surplus then needs to be risk-weighted for credit risk in accordance with Part Three of the CRR. However the CRR is silent on the risk weighting assets for total pension assets. Should pension funds in total, or just the accessible surplus, be risk weighted?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1567
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 17/07/2015

Reporting of % values in LE reports

What is the correct reporting value of % in LE templates?

  • 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: 2014_1564
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reporting of Counterparties on LE2 and LE3 Templates - connected counterparties

Where there exists a group of connected counterparties (i.e. a Parent company and its subsidiary) and the reporting institution has an exposure to the subsidiary but not the parent, can you please clarify whether the code reported on the LE2 template should be that of the parent company or that of the subsidiary. Additionally, where there exists a group of connected counterparties, but the reporting institution only has exposures to one member of the group, should this exposure be detailed on the LE3 template thereby linking the exposure to the parent entity?

  • 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: 2014_1562
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 10/07/2015

Identification of encumbered assets when using collateral pools

Are institutions allowed to report the least liquid assets as encumbered first when a pool of assets of the institution is used as collateral for a liability?

  • 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: 2014_1558
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/06/2021