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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.

List of Q&A's

Reporting of balances denominated in renminbi CNY and CNH in C22 MKR SA FX

In C22 MKR SA FX, where a bank is permitted to hold positions denominated in CNY and CNH, should CNH balances be combined with CNY balances in Row460, or included in Row470 under Other currency positions on the basis that CNH has its own readily-verifiable exchange rate and exposure against the reporting currency? For C22 Row020, if CNH balances are reported in Row470, should CNH be included in List of Closely correlated currencies against the Chinese Yuan (CNY) in Annex 1 to ITS ON CLOSELY CORRELATED CURRENCIES UNDER ARTICLE 354(3) OF REGULATION (EU) 575/2013?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Validation Error arising from Guidance Notes for C 18.00 report

Which one should take precedence:(1) the general remarks for template C 18.00 in the ITS on Supervisory Reporting (Annex II), or(2) the existing formatting for the currency sheets of template C 18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Reporting of financial asset sales and write-offs in FINREP template F 02.00

How should financial asset (e.g. loan portfolio) sales and write-offs be reported in the template F 02.00 (Statement of profit or loss)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Fair value changes due to changes in cross-currency basis spread eligible for CET1 capital (cost of hedging)

Are fair value changes due to changes in cross-currency basis spreads recognized in ‘other comprehensive income’, as referred to under IFRS 9 as the ‘cost of hedging’, eligible for CET1 capital under the CRR regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

EBA COREP Validation Rules on C 05.01

Row 140 column 060 is required to have a value that is less than or equal to zero. That is specified by validation rule v5016_s. In addition, the value in row 140 column 060 includes data entered into row 380 col 060. Were the value in the latter cell entered as a large positive, it is possible that the resulting figure in row 140 column 060 would be positive. Should there be a constraint placed on the value in row 380 column 060?

  • 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)

Validation rule v4792_m, C 12.00 - Securitisations

In C 12.00.a, the validation rule v4792_m is (r030;040;050;060;070;080;090)] {{c050}} <= {{c010}} Since row 30 (ORIGINATOR: TOTAL EXPOSURES) represents the totals for Originators, the above might not hold true in cases where significant early amortization exposures are present. This is because the row 100 for early amortization is greyed out for the columns 010 to 040 in the report template and hence is not considered in row 030 for these columns. However, row 100 is not greyed out for the column 050 where the validation check is applied.

  • 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)

Question on CSD capital requirements and investment policy

For collateral to be considered of the best quality for the purpose of CSDR Articles 59(3)(d) and 59(4)(d), debt instruments are required to be liquidated “on a same day basis”. In the same manner, the appropriate timeframe in order to access the asset under the investment policy, as provided by art. 82(2), should be “on the same business day” We ask European Authorities to clarify the meaning of “same day basis” and “same business day” and the settlement period linked to it.

  • 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)

Reference to Chapter III in Article 96(3)(b)

Is the reference to Chapter III in Article 96(3)(b) correct?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Enforce a third country resolution proceeding

How should the outcome under Article 94(4)(d) be achieved and in what way is that article different from the provision under Article 68?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification on the authority responsible for the DGS

Which exactly is the authority responsible for the DGS referred to in Article 88?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Other groups or colleges in Articles 88(6) and 89(4)

Could you please explain what “other groups or colleges” can carry out the work assigned to the resolution colleges with regard to Articles 88(6) and 89(4)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Intervention of the resolution fund to cover for losses due to creditors / liabilities excluded from bail-in

Can Article 101(2) of Directive 2014/59/EU (BRRD) be interpreted in the way that even if all bail-inable creditors have been subjected to bail-in and losses are still not covered, a bridge bank would not be allowed to take on the remaining losses and thus resolution would not be possible?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification regarding the consideration in Article 42(6)

Can you please clarify Article 42(6) of Directive 2014/59/EU (BRRD); regarding that the consideration can have a nominal or negative value? Does effect of this mean that the asset management vehicle (AMV) must owe a debt to the institution under resolution?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Valuation in Article 36

How should the resolution authority perform the valuation mentioned in Article 36 of Directive 2014/59/EU (BRRD) before making the decision initiating resolution if it is not entitled to require certain information from the particular entity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Conditions for Early intervention

What are the conditions for Early intervention in Article 27(1) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of 'explicit guarantee arrangements' for the purpose of classification of non-commercial undertakings as public sector entities

What conditions should be met by a given agreement in order to qualify as an 'explicit guarantee arrangement'?Shall the ‘explicit guarantee arrangements’ for the purpose of definition of public sector entities also be ‘guarantees’ eligible as unfunded credit protection or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Validation rule v_1044_m (FINREP template 16.3 IFRS9)

The validation rule v1044_m requires that for template F 16.03 the following condition is fulfilled: {r090} = sum(r010-080).However, in taxonomy v2.7 template F 16.03 has been amended: row 015 (of which: Economic hedges with use of the fair value option) has been added. Is the validation rule v1044_m still valid?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Reporting reference dates for template C 33.00

Could you please confirm what the first reporting reference date for the sovereign exposures template (C 33.00) for institutionsi. who report on a calendar year basis (i.e. accounting reference date 31 Dec)ii. whose accounting reference date deviates from the calendar year (say 31 March) and are permitted to apply Article 2(3) of Regulation (EU) No 680/2014is?

  • 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)

ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template

How should (banking) holidays and weekends be reflected in C 70.00 (zeros, empty lines or constant volumes)? How should an internationally active credit institution with subsidiaries in different countries reflect holidays in different countries and working days in the weekend? Is there a different approach to be taken for non-maturity funding versus term funding in light of weekends and (banking) holidays?

  • 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)