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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

How to report liabilities with notice period in C69.00 and C70.00

How can evergreen repos be reported in the C69.00 template? How can deposits with notice period > 1 day be reported in the C69.00 and C70.00 template?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_5794
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Disclosures of Staff expenses Management body in its supervisory function in FINREP Template 44.4

In the countries where we operate supervisory board and management board are two separate bodies. The supervisory board also has members which are not employed by the reporting entity but still receive remuneration for their function. We would like to understand, if this remuneration has to be presented in template 44.4 column 0040 and if yes, should those external remuneration be presented consequently in staff expenses (FINREP Template 2 - Statement of profit or loss in a r370, c010 )?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2021_5793
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Combined buffer requirement on top of MREL consolidation level

Assuming that the consolidated resolution group level pursuant to Article 45c (3) BRRD does not correspond to the prudential consolidation level in accordance with Article 11 CRR, which consolidation level is relevant in terms of distribution restrictions according to Article 16a BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5792
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 09/06/2023

Supervisory Benchmarking Exercise, Annex VI, C107.01, row 0010, column 0020

Is row 0010, column 0020 of C107.01, as specified in Annex VI expected to be filled in as compulsory field?

  • 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: 2021_5791
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Applicability of fix amount dividend policy to mutuals, cooperative societies, saving institutions and similar institutions

Is Q&A 4731 applicable to mutuals, cooperative institutions, savings institutions and similar institutions?

  • 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
  • ID: 2021_5787
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Underlying exposures of securitisations and calculation of the applicable amount of insufficient coverage for NPE for the purpose of calculating deductions from CET1 items

Are underlying exposures of a traditional or synthetic securitisation, for which the originator has either: i) achieved Significant Risk Transfer (SRT) as per Article 244(1)(a) or Article 245(1)(a); or ii) following the full deduction approach as per Article 244(1)(b) or Article 245(1)(b) in or out of scope of the minimum loss coverage requirement for non-performing exposures (see Article 36(1)(m) and Article 47a CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5785
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as final Q&A: 03/03/2023

Elaboration of the template EU LIQ2 using supervisory data EBA/ITS/2020/04 - Annex XIII - Template EU LIQ2: Net Stable Funding Ratio

There seems to be inconsistencies at the level of the mapping tool for the elaboration of the template EU LIQ2 using superviosry data: specifically, while in CoRep templates C80 and C81 the assets/liabilities with no maturity are included in the "less than 6 months maturity" band, in the disclosure template these items are requested separately. This is inconsistent with the indications provided by the mapping tool: can the mapping tool be ignored?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5782
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Interest expenses categories

Under which heading of interest expenses should be declared commissions paid on commitments received ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_5778
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Classification of derivative exposures in a CIU for standardised approach

How shall own funds requirement for a CIU be reported in COREP template C07.00 for standardised approach, in case the underlying exposure is a derivative, and the exposure value is calculated in accordance with Article 132a of CRR2 and using the methods laid down in the Chapter 6? Are institutions allowed to report the underlying derivative exposures in a CIU in rows 0070 – 0080 of template C 07.00 as on- or off-balance sheet exposure subject to credit risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_5774
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/10/2022

Maturity calculation under IRB for exposures that only have contractual cashflows in the form of fees

Does Article 162(2)(a) of Regulation (EU) No 575/2013 (CRR) apply to exposures for which cash flow schedules contractually payable by the obligor are only fee-related (e.g., as in the case of guarantees)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5773
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Deductions

The capital items and instruments in the NSFR shall be reported prior deductions. The deductions should be reported as other assets with a RSF of a 100% (Article 429o, point (a), CRR). Should the off-balance deductions be reported on this row as they need an associated RSF, or they shouldn’t be reported at all?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_5772
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Money broking

What specific services and products are part of money broking?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5771
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 22/12/2022

Qualifying holdings assessment pursuant to the exercise of resolution powers

In the context of the application of resolution tools or the exercise of resolution powers under Directive 2014/59/EU (BRRD), that may imply the creation or increase of qualifying holdings, does the exercise of control by a resolution authority over an institution under resolution or of some or all the rights and powers conferred upon the shareholders of an institution under resolution make the resolution authority subject to the prudential assessment envisaged by Article 22 CRD? Where the RA of Member State A applies resolution tools or exercises resolution powers in respect of an entity under resolution located in Member State A, which owns qualifying holdings in an entity located in Member State B, is the RA of Member State A subject to the prudential assessment of the competent authority of Member State B in as much as holder of indirect qualifying holding?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5765
  • Topic: Interactions with the CRR / CRD IV and the BRRD
  • Date of submission:
  • Published as final Q&A: 22/12/2022

Obstacle to the provision of payment initiation and account information services

Should Article 32.3 of Regulation (EU) 2018/389, read together with paragraphs 33 to 41 of the Opinion of the European Banking Authority on obstacles under Article 32(3) of the RTS on SCA and CSC, be interpreted so as to consider that interface implementations that require, in a redirection approach, Payment Initiation Services Providers (PISPs) to always transmit the payer’s IBAN to initiate a payment order, are an obstacle to the provision of payment initiation services because the payment service user is required to manually enter their IBAN while in the PISP’s domain? Should Article 32.3 of Regulation (EU) 2018/389 be interpreted identically where the interface implementations require Account Information Service Providers (AISPs) to always transmit the IBAN(s) of the account(s) to be accessed, therefore requiring the payment service user to manually enter their IBAN(s) while in the AISP’s domain?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_5763
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Homogeneously managed exposures

How should “homogeneously managed exposures” be understood for the definition of “type of exposures”, which then in turn defines the scope of a “rating system”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5762
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 07/09/2022

Assignment to grades or pools

Do the requirements in Article 171(2) CRR refer to the Estimation of Risk Parameters or to the Application of Risk Parameters?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5761
  • Topic: Model validation
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Treatment of guaranteed export financing transactions under Standardised Approach

Under the Standardised Approach for credit risk, can institutions apply a 0% risk weight to the guaranteed part of export financing transactions if (i) the loan is denominated and funded in the domestic currency of the central government acting as guarantor and (ii) the guarantee is also denominated in this currency while the domestic currency of the borrower is different?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5760
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

On the access to safeguarding accounts through the Application Programming Interface (API)

Shall a safeguarding account of the e-money institution (EMI) or/and of the payment institution (EMI and PI) within the account servicing payment service provider (ASPSP) be considered as a payment account and therefore should be accessible (displayed) through the Application Programming Interface (API) of ASPSP?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5755
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 06/01/2023

Definition of exposures arising from mortgage lending

Which value of the exposure is the amount that can be reduced, when referring to "the pledged amount of the market value or mortgage lending value of the property concerned, but by not more than 50 % of the market value or 60 % of the mortgage lending value”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5756
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 10/02/2023

Treatment of cured defaulted exposures

For the treatment of cured defaulted exposures, a probation period of 90 days with no default triggers must apply before the exposure is moved back to a non-defaulted status. According to Article 178(1)(b CRR) default shall be considered to have occurred with regard to a particular obligor when the obligor is more than 90 days past due on any material credit obligation. However, if the material arrears fall below the thresholds, the arrears counter will reset to 0. Should the probation period of 90 days with no default triggers apply before the exposure is moved back to a non-defaulted status?

  • 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: 2021_5754
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/12/2021