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List of Q&A's

FINREP Loan commitments, financial guarantees and other commitments received

How shall off-balance sheet exposures be reported in first FINREP reports if the data is not available in the accounting systems? Can a starting date for collecting this dta be set?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_125
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - template F. Loans and advances by product, by collateral and by subordination

How shall breakdown of loans according to product, collateral and subordination be reported if collateral information is not available to together with product?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_124
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - template F7 Accumulated write-offs

How shall accumulated write-offs be reported in the first reporting reference dates when all data may not be available?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_123
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP Past due but not impaired < 30 days

Can materiality thresholds be applied when reporting "technical" past due exposures?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_122
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP Amount of cumulative changes in fair value due to credit risk

In the absence of accurate information how the amount of cumulative changes in fair value due to credit risk should be reported? This question is also relevant for templates F4.2, F8.1, F16.5, F45.1.

  • 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: 2013_121
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP, interim dividends

What amount should be reported on row 260 of template F1.3, the dividends distributed during the year or the proposed dividends for the financial year?

  • 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: 2013_120
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: Requirement to submit financial information

If a credit institution prepares consolidated accounts - under IFRS - for Statutory Reporting and is a non public company, and the subsidiary company's activities (a non-credit institution) are below the thresholds mentioned in Article 19 (a) and (b) of the Regulation (EU) No 575/2013 (CRR), can you confirm that it will not be mandatory for the credit institution to submit Financial Information (FINREP), effective from January 1st 2014?

  • 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: 2013_119
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/10/2013

FINREP application date and report submission postponement to Q3 2014

The question regards answer to Question ID 2013_26 Does the answer then imply that reporting entities must have made the necessary arrangements by 1 Jan 2014 (given that this is the start of the accounting year of the reporting institution) for financial information to be reported cumulatively from 1 Jan 2014 to the first reference date of 30th September 2014?

  • 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: 2013_118
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/08/2013

IP Losses: Direct and Indirect costs associated with immovable property losses

In relation to direct and indirect costs associated with immovable property losses can the EBA please confirm what costs should be included?

  • 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: 2013_116
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Liquidity: Reporting on liquid assets Annexe XII; C51.00

Let's take a French bank that have an LCR &gt;100% with a liquidity buffer composed by German government bonds. For report C 51.00 (liquidity buffer) the German government bonds should be reported only to 1 of the 6 reporting blocs. As a consequence, German government bonds will be reported in line 340 since they are of extremely high liquidity and of high credit quality. Nothing will be reported into line 440 neither 040. Is that what you expect?

  • 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: 2013_114
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 11/04/2014

FINREP: thresholds applicable to F20.1 - 20.7 (geographical breakdown)

How to interprete the threshold for FINREP templates 20.1 till 20.7: - link in article 5a(4) to COREP table 4 seems not correct; - is the threshold domestic/non domestic applicable for all templates 20.x? - if the threshold is per table: what with annexes 20.4 - 20.7? is the threshold applicable per country of the counterparty?

  • 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: 2013_113
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

COREP: CA5.1 Template (Rows 133, 136 and 138)

With the addition of Rows 133, 136 and 138 into the CA 5.1 template we seek clarification on whether or not these are sub-sets of other Rows, or standalone.

  • 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: 2013_112
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Interpretation of Article 24 of the CRR regarding own funds requirement at solo level

Can the national discretion in Article 24(2) of Regulation (EU) No 575/2013 be applied at solo level, for prudential purposes in spite of the fact that institutions are not allowed according to national legislation to apply IFRS at solo level for general financial reporting purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_110
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 24/10/2014

FINREP - reporting by residence of the counterparty - format of the country code

In which format does the ISO country code (FINREP tables 6, 20.4, 20.5, 20.6, 20.7) need to be reported: Alpha-2 (eg.: BE), Alpha -3 (eg.: BEL) or three-digit numeric (eg.: 056)?

  • 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: 2013_108
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

COREP: CR GB 3 Template

Can the EBA please confirm if there is a threshold below which this template does not require to be completed? Our non-domestic % is circa 0.8% and covers circa 100 countries.

  • 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: 2013_107
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Liquidity: First submission date for Stable Funding template

EBA-ITS-2013-02 Article 18 (7) states: "for the period from 31 March 2014 to 31 December 2014 as a deviation from point (a) of Article 3 (1) the reporting remittance date relating to monthly reporting shall be the 30th calendar day after the reporting reference date". This would mean that the first submission of the LCR template should be by 30 April 2014, but we question whether this should also apply for the first submission of the SFR template? As things stand, it would appear that the first submission of the SFR template should be in line with Article 18 (6).

  • 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: 2013_106
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Treatment of existing Tier 1 and Tier 2 instruments

This question is a supplement to Question 2013_46. For Tier 1 or Tier 2 instruments with an incentive to redeem and quarterly/semi-annual/annual calls beyond the first call date, would these instruments qualify as Tier 2 capital if the issuer gave an undertaking to its regulator and the market that it would not exercise its call option for at least 5 years after the first call date? This would save the issuer the time and expense of having to modify the actual instrument documentation but would achieve a similar outcome in terms of its capital position/quality.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_105
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 13/12/2013

Information to be declared under the concept of "discretionary pension benefits" in the annex of EBA/GL/2012/5 and in annex 2 of EBA/GL/2012/4

(1) What is the information to be declared by institutions under the concept of “total discretionary pension benefits” established in the annex 1 &nbsp;of EBA/GL/2014/07? A. Contributions made, during the year, by the credit institution to the company’s pension scheme, on behalf of the employee as part of their variable remuneration, or B. Amounts to be paid, or already satisfied, by the credit institution to the employees who have left the institution or got retired during the year.&nbsp;(2) What is the information to be declared by institutions under the concept of “total discretionary pension benefits” established in the annex 2 of EBA/GL/2014/08? A. Contributions made, during the year, by the credit institution to the company’s pension scheme, on behalf of the employee as part of their variable remuneration, or B. Amounts to be paid, or already satisfied, by the credit institution to the employees who have left the institution or retired during the year.&nbsp;&nbsp;

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_103
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/11/2013

COREP: Validation rules on draft ITS for C19.00 (MKR SA SEC)

In this return (C 19.00 MKR SA SEC) we are asked to complete the average risk weight (%) for securitisations going through the supervisory formula approach and the internal assessment approach, in columns 260, 290, 490 and 520. The validation rules in Annex XV specify that these % figures are simply added together, as for any other columns on the return. This produces a mathematically nonsensical result. For example, for the total row (row 010) we should add together the average % amounts from each securitisation category, to reach a total average %. The total is thus the sum of the average %s of each row, a figure that owes more to how many rows are being completed than to any particular value. % Would it not be more mathematically sensible to take the average % of the total? In other words, to replace the existing {r010,c260} = {r030,c260} + {r060,c260} + {r090,c260} with {r010,c260} = {{r030,c260} * {r030,c250}} + {{r060,c260} * {r060,c250}} + {{r090,c260} * {r090,c250}} ? Or if this is not suitable, to not calculate the value at all?

  • 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: 2013_102
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

IRB exposure value - Recognition of specific credit risk adjustment for positions measured at fair-value (e.g. IFRS category FVO, HfT and AfS)

Which is the exposure value according to Article 166 (1) of Regulation (EU) No. 575/2013 (CRR) for IRB positions measured at fair value (to p+l or OCI) in the relevant accounting standard, when a separation of credit risk and market risk related fair value changes (e.g. revaluation reserve) for these positions is not possible and therefore not used to cover expected loss in accordance with Article 159 of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_101
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 14/03/2014