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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

Application of different Phase-In Rates for the Deduction of Deferred Tax Assets that Rely on Future Profitability

Article 478(2) of the CRR provides a discretion to competent authorities to apply a slower phase-in rate for the Deduction of Deferred Tax Assets that rely on Future Profitability for DTAs that existed prior to 1 January 2014. A 10% per annum phase in rate is applied for the DTAs that existed prior to 1 January 2014 while all other DTAs that were created post 1 January 2014 are subject to the normal phase in rates of 20% per annum. Clarification is required on how the different phase-in rates should be applied if the amount of DTAs (that rely on Future Profitability) in existence reduces below the initial amount recognised, due not to progressive deduction under the transition rules but rather due to usage against profit ? For example: Assume on 31 December 2014, the DTA balance is 100 which is made up of 60 that existed pre 1 January 2014 and 40 that existed post 1 January 2014. Assume that on 31 March 2015, the DTA balance reduces to 80 due to usage against profits. Should the DTA balance that existed pre 1 January 2014 be adjusted by the negative balances due to the DTA usage against profits i.e. should the slower phase-in rates be applied to the balance of 40?

  • 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

Treatment of a securities lending and borrowing service with regard to the LCR / Traitement d’un service de prêt et d’emprunt de titres en ce qui concerne le ratio de couverture des besoins de liquidité

What is the treatment of a securities lending and borrowing service with regard to the LCR?***FR:Quel est le traitement accordé au ratio de couverture des besoins de liquidité pour un service de prêt et d’emprunt de titres?

  • 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

COREP LE template C 28.00, C29.00

Where do we report deposit on demand in banks and other receivables on LE templates?Where do we report other receivables on LE templates?How should we report total exposures if exclusion of deposits on demand and other receivables causes decrease of total exposure under threshold of large exposure?

  • 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)

C 04.00 (CA4) form rows 740 to 810 - capital buffer reporting

Do rows 740 to 810 of the CA4 form report monetary values or percentages (buffer rates)?

  • 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)

Calculating the threshold of 1% of total liabilities

When completing template C67.00 and C68.00 items exceeding a threshold of 1% of total liabilities are to be reported. For a report in a significant currency, is the threshold of 1% versus total liabilities in all currencies or versus total liabilities in the significant currency?

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

Should only part of total funding be reported in template C 68.00, Annex XX?

A more general question regarding this section, Annex XVIII C 68.00, is that if just part of the total funding should be reported? The cells for retail funding, wholesale funding and unsecured wholesale funding are marked in grey and this usually indicates that nothing should be reported in these cells. Is this correct? Or is it just an error in the template?

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

Should wholesale funding with open maturity be included when calculating average maturity in template C68.00?

Should wholesale funding with open maturity be reported and included when calculating average maturity? If so, should any specific maturity be assumed for calculating average maturity? Retail funding which are sight deposits are marked grey in row 040 and 050 which implies that open maturity should be excluded.

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

Reporting of bilateral bank loans and book value or emission value in template C 68.00?

In column “product name” there are two categories “Retail funding” and “Wholesale funding”. How shall bilateral bank loans without collateral be treated? Shall bilateral bank loans be reported under “unsecured wholesale funding, of which financial customer” (row 120)? In the column “total amount received”, is it the book value or the emission value that should be reported? Moreover we wonder if equity should be considered as funding?

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

Risk weight in CCP-related exposures, rules on 2% AND 4% risk weight

For the purposes of Article 305 (3) is there loss protection if the condition in 305 (2) b) is met but not 305 (2) c)?

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

FINREP – reporting of negative interest

How to report the remuneration of assets with a negative interest rate?

  • 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)

Hierarchy of Permissions between Article 8 and Article 9 of the CRR

The current Level 1 Text of Article 9 of the CRR (i.e. for the Individual consolidation (amended solo) method) refers directly to Article 6(1) which does not cover the Liquidity Provisions of the CRR. In this regard, can we clarify the following issues in terms of the interaction between the amended solo provisions in Article 9 of the CRR and the solo liquidity waiver provided in Article 8 of the CRR: (1) If a bank receives permission for amended solo under Article 9 of the CRR, is a separate permission required for the liquidity waiver in Article 8 in order for the bank to report a single LCR/ Stable Funding/ ALM Return? (2) Assuming the answer to Q1 is yes, does this mean that the bank is required to report under two scopes of consolidation (i.e. amended solo for COREP/ FINREP/AE and Consolidated for LCR/ Stable Funding/ ALM)? (3) Assuming the answer Q1 is no, how should the subsidiaries included in the permission for amended solo be included in the bank's LCR and Stable Funding returns i.e. is the bank still required to submit both consolidated and individual LCR /Stable Funding/ ALM Returns?

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

GL on funding plans: treatment of loans/deposits on demand across different items in Table 1a - Assets (P 01.01)

How should "Other demand deposit (with credit institutions)" be treated across different items of the Table 1A - Assets (P 01.01) in funding plans in order to avoid double counting? Furthermore, is it relevant to exclude loans on demand from the household sector?

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

QRRE loss rate

What is meant by loss rate in this context?

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

Exclusion of intragroup transactions from own funds requirements for CVA risk

Shall intragroup transactions be excluded from the own funds requirements for CVA risk on a consolidated basis when the intragroup counterparty is established in a third country?

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

Annual Contribution of institutions - Rescaling of the risk weight

How to proceed with rescaling of weights of indicators that are not available, as stipulated in Article 20 of the 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

Annual Contribution of institutions - determination of the risk weight / use of indicators

How to construct the specific indicators as referred to in Annex I of DA in cases where the required data / information was not included in the applicable supervisory reporting for a reference year, although equivalent data did?

  • 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

Annual Contribution of institutions - determination of the basis for annual contributions and the risk weight / use of CRDIV/CRR terminology

What information / data shal be used when determining the annual contributions to resolution financing arrangements in situations, where information required by specific indicators as referred to in Annex I and II of DA is not included in the applicable supervisory reporting for the reference year, e.g. due to inapplicability of the CRDIV/CRR?

  • 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

Annual contribution of institutions newly supervised, institutions non existent in the reference year for contribution calculation, and institutions that ceased to be supervised

How to apply a requirement of the Article 12 of DA to determine a partial contribution calculated during subsequent contribution in case newly supervised institutions, institutions that ceased to exists / be supervised, and the institutions that were not existent in time in the reference year for contribution calculation as detailed in Article 14 of DA?

  • 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

Exclusion of Intragroup Liabilities -Treatment of intra-group derivative contracts

How to apply requirement of Article 5 (4) to substitute any accounting value of liabilities arising from derivative contracts by a corresponding value determined in line with Article 5 (3) and possibility to exclude specific intra-group liabilities according to Article 5 (1) a)?

  • 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

Exclusion of Intragroup Liabilities - General Rule

"Does the criterion of Article 5 (1) a) ii) of DA ""each institution is included in the same consolidated supervision according to Artices 6 to 17 of Regulation No 575/2013 (EU) on a full basis"" alows also intragroup liabilities between ""sister"" companies to be excluded while calculating individual ex ante contributions to resolution arrangements?"

  • 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