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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

Calculation of own funds requirements for CVA risk on a consolidated basis

How shall the own funds requirement for CVA risk be calculated for consolidated group of institutions?

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

Equivalence of third country supervisory and regulatory arrangements to those applied in the Union

Who decides which third countries apply supervisory and regulatory arrangements at least equivalent to those applied in the Union? Unlike other articles in CRR (such as e.g. Article 114(7)), Article 212 does not explicitly empower the Commission to adopt, by way of implementing acts, and subject to the examination procedure referred to in Article 464.2, a decision as to whether a third country applies supervisory and regulatory arrangements at least equivalent to those applied in the Union.

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

Equivalence of third country supervisory and regulatory arrangements to those applied in the Union

Who decides (after the transitional period, if applicable) which third countries apply supervisory and regulatory arrangements at least equivalent to those applied in the Union in case the Commission does not make use of its power to adopt, by way of implementing acts, and subject to the examination procedure referred to in Article 464(2), a decision as to whether a third country applies supervisory and regulatory arrangements at least equivalent to those applied in the Union?The same question occurs with regard to Articles 107(4), 115(4), 116(5), 132(3) and 142(2) CRR.

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

Reporting of derivatives

In the Asset Encumbrance template derivatives with a negative market value should be reported. Have the value of the derivatives be reported after netting?

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

0% Risk Weight Exposure Public Sector Entities

In reference to the requirement under ID 3.3.4 transferable securities with a 0% risk weight... representing claims on or claims guaranteed by non-central government public sector entities (Annex XII – Liquidity ration template). Under Chapter 2, Title II of Part Three, Exposures to public sector entities shall be assigned a risk weight as per Art. 116 or as per Art. 116(2) shall treat in accordance with Art. 120. In any case, none of this guidance indicates a 0% Risk Weigh for public sector entities.

  • 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)

Standardised Method

If the derivative exposure is guaranteed, can the weight be determined based on guarantor’s rating instead of counterparty’s rating, i.e. do we use the counterparty’s credit rating or the guarantor’s rating?

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

Non material losses

The definition of what is a non-material loss is not defined within Article 472 of Regulation (EU) No 575/2013 (CRR); is it possible to clarify what ‘material’ / 'non-material' is? Can you advise how- if applicable- such non-material losses are treated?

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

Original Exposure pre-conversion Factors

The draft ITS on Supervisory reporting state that the Exposure value (for on-balance sheet exposures) equals to the exposure value without taking into account value adjustments and provisions, conversion factors and the effect of credit risk mitigation techniques. However, article 111(1) states that "The exposure value of an asset item shall be its accounting value remaining after specific credit risk adjustments". Additionally, the accounting value of an exposure is net of certain value adjustments e.g. non-recoverable income, etc. If for example, we have a customer loan with the following data: A. Balance: 100 B. Non-recoverable income -10 (usually from non-accrual status) C. Gross Accounting value (A+B) 90 D. Provisions -20 E. Net Exposure (C+D) 70 What is the Original Exposure pre-conversion Factors, A or C?

  • 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)

Contradiction between CRR and Draft ITS on Supervisory Reporting of Off-balance items

Following the CRR annex I we should report off-balance: (b) credit derivatives;(c) acceptances;(d) endorsements on bills not bearing the name of another institution;(e) transactions with recourse (e.g. factoring, invoice discount facilities);(g) assets purchased under outright forward purchase agreements;(j) asset sale and repurchase agreements as referred to in Article 12(3) and (5) of Directive 86/635/EEC; Following the Draft ITS on Supervisory Reportingparagraph 60 these items should never be reported off-balance

  • 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)

Reporting LE in accordance with Art 392, 20 largest exposures according to last sentence of Art 394(1), 10 largest exposures to institutions and 10 largest to UFE according to Art 394(2)

Do we have to report 4 separate lists? i.e. List 1: LE1, LE2 and LE3 for large exposures defined in accordance with Art 392 (ref. Art 394(1)), including LE exempted from the application of Art 395(1) List 2: LE1, LE2 and LE3 for 20 largest exposures according to the last senctence of Art 394(1), excluding those exempted from the application of Art 395(1) List 3: LE1, LE2, LE3, LE4 and LE5 for 10 largest exposures to institutions according to Art 394(2), including LE exempted from the application of Art 395(1) List 4: LE1, LE2, LE3, LE4 and LE5 for 10 largest exposures to unregulated financial entities according to Art 394(2), including LE exempted from Art 395(1) In which case a particular group of connected clients may show up in several lists (e.g. group XXX shows up in list 1 and in list 2) OR do we have to provide one instance of LE1, LE2, L3, LE4, LE5 such that a particular group of connected clients shows up only once in LE1, LE2 etc.?

  • 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)

Reporting of liquid assets as per annex III CRR

In the C51.00 liquid assets template, should columns 030 and 040 be greyed out for rows 340 to 360 and columns 010 and 020 be greyed out for rows 370 to 390?

  • 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)

Reporting of liquid assets as per annex III CRR

Should items under lines 3.1, 3.2, 3.9 and 3.10 in section 3 of the C51.00 template be reported up to their amount, as items under 1.1, 1.2, 1.5 and 1.6 lines, or at their market value as specified in the template?

  • 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)

Liquidity-sub group

In Article 8 (1) of Regulation (EU) No. 575/2013 (CRR), it is stated, that institutions may fulfill the liquidity requirements on a liquidity-sub-group level, if the subsidiaries are located in the Union resp. Article 8 (3) deals with liquidity sub-Groups in several member states. Is it also possible to build-up a liquidity sub-group, if one of the subsidiaries is not located in the Union, but the country is member of the EWR (esp. EFTA member like Liechtenstein, Iceland and Norway)?

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

Scope of application of FINREP

Our question concerns Article 99(4) of Regulation (EU) No. 575/2013 (CRR). Does it empower national competent authorities to determine, in respect of smaller non-systemic institutions that for whatever reason use international accounting standards/ IFRS (and thereby fall under paragraph (2)), that such institutions need not be required to report financial information as envisaged in Article 99 (2)? This would be on the grounds that such information is not necessary either to obtain (i) a comprehensive view of the [individual] risk profile of such institutions; or to obtain (ii) a view of the systemic risks posed by such institutions [collectively] to the financial sector or the real economy.

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

Validation Rules

Can the validation rules (in Annex XV, from row 1160 till 1178) for the template C61.00 "Stable funding - items providing stable funding' be deleted?

  • 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)

Highly leveraged obligors

How to define/identify 'highly leveraged obligors' under Article 180(1)(a)?

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

Interpretation of Article 325b of Regulation (EU) No 575/2013 (CRR)

1. Are the conditions set out in Article 325b (2) CRR conditions that have to be simultaneously met with respect to every single institution and undertaking (parent and subsidiaries) no matter whether it holds positions that shall actually be offset on a consolidated basis? 2. Analogously, are the conditions set out in Article 325b (3) CRR conditions that have to be simultaneously met with respect to every single undertaking in a third country no matter whether it holds positions that shall actually be offset on a consolidated basis?

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

Scope of "undertaking" in Article 325 (1) of Regulation (EU) No 575/2013 (CRR)

Does the term “undertaking” in Article 325 (1) of CRR refer to financial sector entities as well as other legal business entities outside the financial sector? If not, to which does it refer?

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

Gross amount of intangible assets

Should the institution report in COREP other intangible assets in gross amount not net as today it's 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)