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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

Scope of Article 208 CRR

Does Article 208(3)(a) CRR require institutions to monitor property values of all commercial properties on a yearly basis, regardless of whether they can qualify as eligible collateral for credit risk mitigation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5470
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Regarding payments between PSPs

1) Are the credit institutions obliged to request payment service providers to disclose payment details as described in the Regulation (EU) 2015/847 in case of batch file transfers? 2) If yes, to what extent should the obligation to disclose payment information be applied?

  • Legal act: Regulation (EU) 2015/847 (WTR) (recast)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5463
  • Topic: Other topics
  • Date of submission:

Outflows from deposits in insurance wrappers

Can cash deposits in insurance wrappers be treated like deposits by Personal Investment Companies (PIC) when computing outflows in the LCR?

  • 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: 2020_5461
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Annex V reference to ESRB Recommendation on closing real estate data gaps

Annex V to Regulation 680/2014, specifically Part 1.5(m) refers to ‘ESRB recommendation on closing real estate data gaps’ specifically to the 31 October 2016 version (ESRB/2016/14). Should this be interpreted as such that the definitions from ESRB/2016/14 are applicable for Finrep reporting, and the amended definitions from ESRB/2019/3 are not? Is this interpretation valid for both the currently applicable EBA framework 2.9 as well as for the announced (with final Annexes already available) EBA framework 3.0?

  • 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: 2020_5458
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

LtV calculations in FINREP

Should only ‘commercial immovable property collateral’ be included in the LTV calculations to be reported in Finrep templates F18.02 and F23.03? Additionally, should any collateral value allocation be applied in these same LTV calculations in case a ‘commercial immovable property collateral’ secures both an outstanding loan and at the same time an off-balance sheet item, or can the full commercial immovable property collateral value be allocated to the outstanding loan amount?

  • 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: 2020_5457
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

FINREP Template 25.01 FX results and vintage buckets

In template F25.01 Collateral obtained by taking possession other than collateral classified as Property Plant and Equipment (PP&E): Inflows and outflows is requested. How do we report FX differences for the period and especially for the vintage buckets (columns 0050-0100)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2020_5456
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Synthetic securitisatios

Can ‘vendor financing’ constitute a synthetic securitisation?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5454
  • Topic: Provisions applicable to all securitisations
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Credit faclity level

Is it possible to assign default according to the purpose of the loan (e.g only the exposure that was granted for renovation) and treat it as at facility level or not? In case of one agreement for 2 purposes and 2 amounts granted, from the regulatory perspective can we treat such approach as default assignment at facility level or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2020_5447
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Institution responsible for compliance with the requirements on a consolidated basis in a horizontally consolidated group

According to which provision of the CRR/CRD an institution shall be determined to comply with the requirements on a consolidated basis and to fulfil all requirements on the basis of the consolidated situation? Can Articles 18(3) and 18(6) CRR determine which institution in a horizontally consolidated group shall be responsible for compliance on a consolidated basis and for fulfilment of all requirements on the basis of the consolidated situation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5444
  • Topic: Other issues
  • Date of submission:

COREP C17.01 - Consistency of the EBA Taxonomy control v5839_m

Does the Control v5839_m take into consideration the possibility to report a correlated incident?

  • 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: 2020_5434
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Treatment of deducted exposures in the calculation of memo items “Risk-weighted exposure amount under SEC-ERBA” and “Risk-weighted exposure amount under SEC-SA” ({C14.01 c447} and {C14.01 c448} respectively)

How to treat deducted exposures in the calculation of the mentioned memo items, to allow for a coherent and homogeneous comparison between the own funds required by the different methods?

  • 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: 2020_5422
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Sign convention for “Credit risk adjustments during the current period” {C14.00 c225} and definition of "current period".

The sign convention that should be followed to report credit risk adjustments in column 225 of C14.00 is not clear. In the same way, the “current period” should be further specified.

  • 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: 2020_5421
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Weighting of EVE gains of domestic currency by a factor of 50% when calculating the aggregate EVE change for each interest rate shock scenario

When calculating the aggregate EVE change for each interest rate shock scenario, should EVE gains of the domestic currency (i.e. EUR in most cases) be weighted by a factor of 50% or should such gains be weighted by a factor of 100%?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/08 - Guidelines on the management of interest rate risk arising from non-trading activities
  • ID: 2020_5419
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Resolution planning for an established subsidiary part of a cross-border group with no Resolution College established

Please specify how the tasks referred in Article 88(1) of the Directive 2014/59/EU (BRRD) should be carried out in practice in case the group-level resolution authority has not set up a Resolution College? Should the resolution authority prepare and maintain resolution plan on an individual basis in respect of a subsidiary failing under its jurisdiction, which is part of a cross-border group, in case the Resolution College for the group has not been set up yet?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5403
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as Rejected Q&A: 16/12/2022

EBA validation rule v7365_m

Is v7365_m stating that for the C14.00 if ({c040} = [eba_RT:x10] or {c040} = [eba_RT:x11]) then {c140} <= {c130} correct?

  • 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: 2020_5402
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Credit risk framework applicable to investments in repack Notes issued by SPEs

What is the applicable credit risk framework in the non-trading book applicable to investments in repack Notes issued by Special Purpose Entities (SPEs)? How should an institution calculate the risk weight of an investment in a Repack Note if it does not consolidate the SPE but is able to look through to the underlying assets at all times?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5400
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

FINREP Payment services Template 22.2

The definition of Payment services has been updated in the FINREP DPM 2.9.2. Can the information asked in template 22.2 row 120 Payment services be removed?

  • 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: 2020_5399
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Mapping to exposure classes

Are Greenland, Faroer, Guernsey, Isle of Man and Jersey to be treated as "central goverments" under Article 112(a) CRR or are they to be treated as "regional governments" under Article 112(b) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5392
  • Topic: Credit risk
  • Date of submission:

Obligor level

When applying the default at obligor level for retail, should a credit institution always consider a specific set of individual obligors that have a joint obligation towards an institution as a different obligor (the unit of default takes into consideration the JCO)? Or is this to be applied only for the materiality threshold?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2020_5380
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/07/2021