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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.

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List of Q&A's

LCR treatment of cashier’s cheques

What should be the correct LCR representation of a cashier’s cheque in terms of outflow rate and ITS category according to the C73 template? Is it appropriate to consider the amount net of the collateral posted?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

factor to apply to non performing exposures to which a risk weight is 0% in a performing situation for the purpose of calculating the amount of unsufficient coverage

is it possible to consider that the derogation applied to the part of the non-performing exposure guaranteed or counter-guaranteed by an eligible protection provider referred to in Article 201(1), points (a) to (e), the unsecured exposures to which would be assigned a risk weight of 0 % under Part Three, also applies to unsecured exposures themselves when assigned a risk weight of 0% ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/06 - Guidelines on management of non-performing and forborne exposures

SOLVENCY TREATMENT: SECURITISATION POSITIONS SUBJECT TO OWN FUNDS REQUIREMENTS C14.00 Col 0060 – reporting requirement is inconsistent between the ITS and the latest version of the EBA Annotated Tables and EBA P3 mappings for templates EU-SEC1 and EU-SEC3

ANNEX II INSTRUCTIONS FOR REPORTING ON OWN FUNDS AND OWN FUNDS REQUIREMENTS C14.00 Col 0060 states the following: “Originators, only, shall report one of the following:  - Not subject to own funds requirements. - Banking book; - Trading book; - Partially in banking and trading book.” Question 1. The latest version of the EBA Annotated Tables for C14.00 col 0060 references the Role in the securitisation process = Originator, Sponsor.  This is inconsistent with the ITS, which refers to Originator securitisation exposures only.   Can we clarify whether EBA has expanded the scope of reporting for col 0060 to also include exposures where the Role in the securitisation process = Sponsor?  This is not a change that has been noted as part of CRR3 uplift requirements work. The associated EBA mapping logic for Template EU-SEC1, sections h to k, where Institution acts as sponsor for example (noted below) - the conditions are mutually exclusive, as within the current reporting process, C14.00, col 0060 is only populated in instances where the Role in the securitisation process = Originator. if(and({C 14.00, c0061} = N, {C 14.00, c0080}=A or D), {C 14.00, c0140}*{C 14.00, c0090}, if({C 14.00, c0061} ≠ N, {C 14.01, c0411})), where  {C 14.00, c0060} = Banking book,  {C 14.00, c0110} = Sponsor   Question 2. The reportable values noted above are consistent between the EBA annotated tables and the ITS, however the EBA mappings for Template EU-SEC1 and Template EU-SEC3 is limited to instances where C 14.00, c0060 = Banking book only.  Is it an intention of the EBA to only capture the banking book securitisations in these templates?  This is not in line with the scope of production P3 disclosures, which also considers values other than Banking Book.  

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

Definition of Net defined benefit assets [Carrying amount] in F44.01

Please can we clarify what is required in row 0090 of FINREP template F44.01 in terms of the "Net defined benefit assets" ? i.e. should this row only include surplus amounts that shall be recognised in the balance sheet given that the previous sign validation rule v3985_s has now been deactivated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

EBA Funding Plan return - Annex 1 - 2.3.1 (P01.02) and 9.1 (P05.00)

Guidance is needed on why there is a specific AT1 issuance/maturity section under debt securities/liabilities in P01.02,r191,c010 & P05.00, r0030 & r0040, c10-40 whereas under IFRS and therefore FINREP they are included in equity. This is leading to a validation error with FINREP which we would like the EBA to consider on the most appropriate way to resolve for the completion of the Funding Plan return.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/05 – Guidelines on harmonised definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2 - repealing EBA/GL/2014/04

Pillar 3 Disclosure - EU OV1 – Row 1 ‘Credit risk (excluding CCR)’ mapping clarification

In Template EU OV1, Row 1 "Credit Risk (excluding CCR)", we observe that the current mapping includes the following components from C 02.00: {C 02.00, r0690, c0010} – Other risk exposure amounts minus {C 02.00, r0720, c0010} – Requirements for large exposures minus {C 02.00, r0755, c0010} – Additional RWEA for market risk imposed by supervisor (Art. 110) minus {C 02.00, r0770, c0010} – Additional RWEA for market risk minus {C 02.00, r0780, c0010} – Transitional RWEA for crypto assets (Art. 501d(2))   While this mapping appears to isolate the portion of "Other RWA" not related to market risk, large exposures, or crypto assets, our understanding is that the total reported in row 0690 may still include other risk exposure amounts arising from non-credit risk categories, such as CCR (e.g. RWA induced by IMM PMA). Given that Row 1 of EU OV1 is intended to reflect credit risk excluding CCR, we would like to confirm whether including the residual amount from r0690 (after the above deductions) is appropriate, or if this could lead to misclassification of non-credit risk RWA under credit risk.

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

Structural Differences Between Annotated Table Layout and Taxonomy in GSIIDISPILLAR3 under DPM 4.1

Which representation (annotated table or taxonomy/XBRL) should be considered authoritative for defining the expected scope of data points for reporting? Should institutions follow the taxonomy-enabled structure and report values in cells that are greyed out in the annotated table, as shown in the sample XBRL file?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)

Validation rules taxonomy V4.0 C_17.01

The formulae v23510_h seems not relevant

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules taxonomy V4.0 C_17.01

The formula of control v23509_h seems not relevant

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Justification to consider a ‘significant penalty’ and to be excluded from the outflows

Pursuant to article 25(4)(b) of Delegated Regulation (EU) 2015/61, does the cumulative loss of accrued interest, representing more than 50% of the total contractual interest income upon early withdrawal of term deposits (specifically those which have been active for more than 50% of their contractual term, have an original maturity longer than 30 days, and a residual maturity exceeding 30 days), constitute sufficient justification to consider this as a ‘significant penalty’ under article 25(4)paragraph (b), with the purpose of discouraging early withdrawal, and therefore allow such retail deposits (for which more  than 50% of contractual term has passed)  to be excluded from the outflows?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

Clarification on column a) "Total exposures", CR7-A Template

Could you please confirm that the coloumn a) "Total exposures" of CR7-A template should be filled with outstanding amount post application of credit conversion factor without taking into account any substitution effects due to the existence of a guarantee  in accordance with Articles 166 to 167 CRR, in case the exposure covered by only unfunded credit protection (guarantees)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR

EBA Mapping Tool Clarification - EU MR3

Template EU MR3 - IMA values for trading portfolios (Row 4/8/12/16) According to the disclosure instruction (Annex XXX) & Article 455, MR3 will need to include related Internal Model Market Risk elements.  However, according to the EBA defined mapping for the above rows, which is mapped to C24.00, some IM elements (e.g. RNIME number) will be missed from the disclosure  

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

Application of the SME definition in specific cases

How shall the SME definition in Article 5(9) of Regulation (EU) No 575/2013 (CRR) be applied in the following cases: 1. The entity is considered both in accounts on the consolidated basis of a group and also in accounts on a “sub-consolidated” basis only considering a sub-group of this group. 2. The entity is a single entity that prepares accounts on its individual basis but is not considered in any accounts for a “consolidated situation” of a group.

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

Exposures to EU exchanges

Should exposures to EU exchanges be treated as exposures to institutions, under articles 119, 120 and 121?

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

Loans collateralized by immovable property in F 05.01 and F 13.01

Do loans collateralized by immovable property in templates FINREP 05.01 and FINREP 13.01 need to comply with Articles 124 - 126 of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Treatment of Subscription Agreements in CIUs as Off-Balance Sheet Item

Clarification is sought on the prudential treatment of subscription agreements entered into for the acquisition of units in Collective Investment Undertakings (CIUs), specifically in the context of off-balance sheet exposures under Article 111(4) of the Capital Requirements Regulation (CRR). More specifically, clarification is sought on the treatment of subscription agreements upon signing of the relevant documentation but which effects, at the time of signing, is subject to the verification of conditions precedent (these conditions normally being out of the control of the subscriber) such as the relevant fund reaching a certain size.

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

Computation of the operational risk valuation adjustment after entry into force of Regulation - EU - 2024/1623

To comply with article 105, point (10) of CRR, and with article 17 of the Delegated Regulation  2016/101 we ask the following two questions:  Does the calculation of own funds requirements for operational risk in accordance with Title III of Part Three of CRR include operational risk relating to valuation processes? If the answer to the question above is yes, does the Delegated Regulation 2016/101 allow to avoid double counting of operational risk relating to valuation processes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR

Credit Conversion Factor Treatment - Loan Participation Agreements in Unconditionally Cancellable Facilities

For loan participation arrangements where Bank A (the issuing bank) originates loans classified as unconditionally cancellable and applies 0% Credit Conversion Factor (CCF) under CRR Article 111, what is the appropriate CCF treatment for Bank B as the participating bank?Specifically, should Bank B apply:- a 0% CCF - consistent with the unconditionally cancellable nature of the underlying loans issued by Bank A- Standard CCF rates (20% or higher) - based on the participation agreement structure, where Bank B cannot directly exercise the unconditional cancellation rights?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions

EBA Mapping Tool Clarification - EU OV1 & EU CMS1

With regards to the mapping logic used for EU OV1 & EU CMS1, in particularly for the Market Risk related rows, these currently reference the new FRTB related reporting templates with the C 90 series. As the implementation of FRTB is set to be delayed by a further year (refer to communication from the European Commission) until 1st January 2027, we believe that the mapping logic should be updated to reflect, referencing back to the pre-CRR3 Market Risk templates C18.00-C24.00, in addition to C02.00. In addition, we feel that in relation to EU OV1 template, the rows associated to Market Risk may require amendment to reflect the pre-CRR3 breakdown, unless the interim requirement is to mirror the approach to the of reporting (in C02.00), where data is reported under the Simplified standardised approach (S-SA) only.

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

fully and completely secured by mortgages for the purpose of the deduction of non performing exposures

In the context of the CRR3 and the application of the deduction of non-performing exposure from Common Equity Tier 1 as per article 47c, we would like to clarify the requirements of “ fully and completely secured by mortgages” in order to determine the "secured part of a non-performing exposure".

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