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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

References to shareholders in Article 34 (and 44)

Are holders of Common Equity Tier 1 (CET1) only to be considered shareholders?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2521
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Determination of exhaustion of supervisory action by the resolution authority

How can the resolution authority determine in the context of the determination that an institution is failing or likely to fail that supervisory action(s) by the competent authority has / have been exhausted and would not prevent the failure of the institution within a reasonable timeframe?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2519
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Application of tools

Does the Commission agree that the Directive must be interpreted in such a way that that the resolution authority should have all the tools available for all institutions so that they can be used depending on the situation, and that it cannot be determined by national legislation, that certain tools (e.g. bail-in) should always be used for the smallest institutions whereas other tools can be applied for SIFIs?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2518
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Additional implementation to Article 27(1)(d)

What additional implementation to that required for Article 27(1)(d) of Directive 2014/59/EU (BRRD) is expected in the light of Article 28, and if so, how can any difference be implemented in compatibly with the European Convention on Human Rights?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2517
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Relation between precautionary recapitalisation and early intervention measures

What is the relation between precautionary recapitalisation and early intervention measures in case an institution would have to raise its capital base following the negative outcome of stress test?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2516
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 28/01/2022

Notification requirements in the context of financial support

What does is the scope of the obligations imposed by Articles 25 (1) and 25 (6) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2515
  • Topic: Intra-group financial support
  • Date of submission:
  • Published as final Q&A: 28/01/2022

References to “the group” in Articles 6 (2) and (5)

Why do Articles 6 (2) and (5) of Directive 2014/59/EU (BRRD) make reference to “the group” althugh the assessment of group recovery plans is covered under Article 8?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2514
  • Topic: Recovery plans
  • Date of submission:
  • Published as final Q&A: 28/01/2022

Calculation of ELGD under the Supervisory Formula Method in case of a re-securitisation

In case of a re-securitisation, in order to calculate the value for ELGD under the Supervisory Formula Method, shall an LGD of 100 % only be applied to those securitised exposures that are securitisation positions or to all securitised exposures where all securitised exposures are to be treated under the Internal Ratings Based Approach (IRBA)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2508
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

Definition of the target level for national resolution systems since 2016

How should national resolution authorities continue calculating the ex-ante contributions of investment firms that do not fall in the scope of Commission Delegated Regulation (EU) 2015/63?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_2507
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Can multiple exemptions be applied to an exposure at the same time?

This question relates to the application of multiple exemptions from article 400 (2) CRR in specific cases. As stated in article 400 (2) CRR „competent authorities may fully or partially exempt exposures“. Which exemption should be applied to an exposure if it falls under the incidence of more than one of the partial exemptions from article 400 (2) CRR? We would like to give an example related to this question. In Germany, a partial exemption of 75% may be applied according to article 400 (2) c) CRR for exposures, excluding participations or other kinds of holdings, incurred by an institution to its parent undertaking, to other subsidiaries of that parent undertaking or to its own subsidiaries, in so far as those undertakings are covered by the supervision on a consolidated basis to which the institution itself is subject, in accordance with this Regulation, Directive 2002/87/EC or with equivalent standards in force in a third country. Furthermore, according to article 400 (2) i) CRR an exemption of 50% may be applied to medium/low risk off-balance sheet undrawn credit facilities referred to in Annex I.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2506
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

RWA Standardised calculation

Could you confirm if RWA Standardised (field c180 of template C103, Annex III) is out of scope until 1.1.2017?

  • 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: 2015_2505
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Template 105.01 filling for LDPs

Should the template 105.01 be filled also for LDPs?

  • 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: 2015_2503
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/06/2016

‘Mortgages’ identification

Are "commercial mortgages" and "other mortgages" excluded from HDPs perimeter?

  • 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: 2015_2501
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Rows 660 – 770 of the template C 60.00 of Annex XII of the ITS on supervisory reporting do not seem to be feasible for the reporting of equities if these are considered as liquid assets. After the application of the LCR Delegated act some equities are considered as level 2B liquid assets. Therefore a solution is needed on where to report these assets in this template.

Where should equities, when considered as level 2B liquid assets, be reported in the template C 60.00 of Annex XII of the ITS on supervisory reporting?

  • 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: 2015_2500
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 15/04/2016

Amounts to be reported under derivatives receivables in C 60.00 (row 1290) and under liabilities from derivatives payables contracts in C 61.00 (row 240) of the - ITS on supervisory reporting of institutions.

Shall the amounts to be reported in derivatives assets or liabilities in rows 1290 and 240 respectively in C 60.00 and C 61.00 of the ITS on supervisory reporting of institutions be deducted by variation margins received or posted or shall they be gross amounts?

  • 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: 2015_2499
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 15/04/2016

C 60.00 Items requiring stable funding – amounts to be reported under rows r040 – 070 and 152 – 153

Shall the amounts to be reported under rows 040 13 070 and 152 13 153 of C 60.00 include also encumbered assets or only unencumbered assets?

  • 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: 2015_2498
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 15/04/2016

C 60.00 and C 61.00 – clarification on the amount extremely high liquidity and credit quality, on the amount high liquidity and credit quality and amount other assets

Which assets in rows 10 to 890 of the template C 60.00 of Annex XII of the Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions - shall be considered of extremely high liquidity and credit quality, of high liquidity and credit quality and as of other assets in the context of items requiring stable funding? The same question arises with respect to the template C 61.00 of the same Annex in rows 070 to 090 and in rows 140 to 160.

  • 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: 2015_2497
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 15/04/2016

Secured central bank lending and liquidity buffer adjustment

Does the liquidity buffer have to be reduced by outflows from secured lending even if the lender is a central bank and the outflow is 0%-weighted?

  • 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
  • ID: 2015_2495
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Allocating transfer from Share Premiun to Other components of equity.

As per the cell { r160, c020} is greyed in F 46.00 template, transfers from share premiun to other items of equity and other increases or decreases are not possible to be reported. On the other hand, the cell {r100, c020} should be used to reclassify "Share Premiun" to "Other reserves" but, this line is not a correct source of equity change, since it is not a reduction of capital but a share premiun. Where or how transfers from share premiun to other reservers must be reported?

  • 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: 2015_2492
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Written Credit Derivatives Add-On MR/NR Netting

Under Article 429d(3) of the Regulation (EU) No 575/2013 (CRR), is it allowable to reduce the Add-On exposure of a written credit derivative (CDS) which has a Modified-Restructuring clause by a purchased credit derivative (CDS) which has No-Restructuring clause (where both CDS contracts have the same maturity, seniority and underlying reference entity)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2015_2491
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 30/06/2017