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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

Validation rules v2815_m, v2821_m vs. FINREP / AE instructions

Validation rules v2815_m and v2821_m imply that customer loans on demand are reported in different rows in the Asset Encumbrance template F 32.01.Our understanding of FINREP and AE instructions differs as follows:In Asset Encumbrance template F 32.01, all loans on demand are reported in row 020 ‘Loans on demand’, whether they are due from credit institutions or customers. In French accounting (PCEC), credit institution loans on demand are classified in class of accounts 1, and customer loans on demand in class of accounts 2.In FINREP template F 01.01, class 1 loans on demand are reported in row 030 ‘Cash balances at central banks’ and class 2 loans on demand in row 200 ‘Loans and advances’.We believe validation rules v2815_m and v2821_m are inconsistent with FINREP and AE instructions on customer loans on demand.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Risk weight for the credit risk for third countries with supervisory and regulatory arrangements at least equivalent to those applied in the Union according to Article 114(7) CRR

If a third country has supervisory and regulatory arrangements at least equivalent to those applied in the Union (such as Turkey) what risk weight for the credit risk is assigned to the exposure of this country?For example, when the Turkish competent authority assigns a 0% risk weight to the credit risk of Turkey, can this risk weight be used by a German bank? What happens when Turkey issued bonds in EUR, USD, JPY and TKY? How is the difference in the risk weight in the case the Turkish competent authority assigns a 0% risk weight to all bonds?

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

FINREP, F 08.01: Breakdown of financial liabilities, amount contractually required to pay at maturity

We need a clarification regarding FINREP template F 08.01 Breakdown of financial liabilities by product and by counterparty sector, column 050 (Amount contractually required to pay at maturity). It is not clear which types of deposit liabilities (overnight deposits, deposits with agreed maturity, deposits redeemable at notice and repurchase agreements (repos)) are required to be included in this column. Does FINREP template F 08.01, column 050 refer to all of the four aforementioned deposit types or only those ‘deposits with agreed maturity’ and ‘repurchase agreements (repos)’? IF we are to include all four types of deposits, it is not clear what maturity date to use for overnight deposits and deposits redeemable at notice.

  • 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)

Application of a Permanent Partial Use exemption under Article 150(1)(d) to the European Commission

Does the permanent partial use exemption under Article 150(1)(d) of CRR encompass European organisations such as the European Commission? Does the permanent partial use exemption under Article 150(1)(d) of CRR encompass European organisations such as the European Commission?

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

Funding Reliances - Table 2A1 - Insured and unsinsured deposits and uninsured deposit-like financial instruments (P 02.01)

Which of the following amount should "Deposits covered by a Deposit Guarantee Scheme according to Directive 94/19/EC or an equivalent deposit guarantee scheme in a third country" definition include: (1) Covered Deposits as per Art. (2) of the European Directive 2014/49/EU on Deposit Guarantee Schemes i.e. all deposits eligible for compensation for each customer with the credit institution up to €100.000 for each depositor. OR (2) Payable amount i.e. all deposits eligible for compensation for each customer with the credit institution after setting-off any credit institution's counterclaims against that specific customer and taking into account the maximum amount of compensation that is €100.000 for each depositor.

  • 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

Treatment of Credit Unions in C 68.00 ALMM Reporting

How should Credit Unions be classified for ALMM 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)

EBA validations APPEAR to be relevant to IFRS and GAAP though they only include a GAAP template (F 04.06)

Can you confirm that these validations are out of scope for IFRS and, if so, why in the EBA validations list their severity is marked as "Blocking for IFRS"?

  • 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)

CCF for uncommitted lines

Can uncommitted guarantee/letter of credit lines be classified as low risk under Annex I, point 4 letter (c) CRR? 

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

Scope of CRR definition of Financial Institution

Are deposits maintained by entities meeting the literal requirements of Article 4(1)(26) CRR excluded from the coverage of the Deposit Guarantee Schemes (DGS)?

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

C 07.00, validation e4894_n (validations for v2.6)

This validation rule indicates that for exposure class ‘Institutions’ rows 140 to 170 and 190 to 280 of C 07.00 for columns 010 to 040 and 150 to 240 should be empty. Where should the following exposures to institutions be reported?According to Article 113 (6) CRR an institution may have exposures which are assigned a RW of 0%, (row 140).According to Articles 306 (1) and 305 (6) CRR, CCPs exposures reported in ‘Institutions’ would take a RW either of 2% or 4% respectively (rows 150 and 160)According to Articles 119 to 121 CRR, an institution may have exposures to an institution which are assigned a RW of 50%, 100% or 150% (rows 200, 230 and 240)

  • 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)

Rollover of Funding (C 70.00): Treatment of maturing deposits being renewed at a different tenor

When the initial tenor of the maturing deposit is different from the rolled over deposit, will the maturing deposit be reported in a different initial tenor section compared to the rolled over deposit?For example, if a deposit is maturing which had an initial tenor of 2 months but when rolled over it has an initial tenor of 9 months, where will the maturing amounts be shown and where the rolled over amount? Do they have to be in the same initial tenor section?

  • 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)

Risk weight to apply to exposures to unrated central banks

What risk weight should be assigned to exposures to the central bank of a non EU-member country when the central bank does not have a credit assessment by a nominated ECAI (i.e., it is unrated)? Would it be appropriate to assign a risk weight of 100% to exposures to said central bank, independently of the rating of the central government?

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

The question relates to systemic risk buffers and whether they can be additive

According to Article 134 CRD can two systemic risk buffers (SRBs) be additive e.g. in situations where a home country already has a SRB in place and wants to reciprocate a SRB from another Member State?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Presentation of IRB floor (Article 500 CRR) in COREP templates

How should an IRB institution present Basel I floor as defined in Art. 500 CRR (an additional IRB floor requirement) in COREP reports?

  • 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)

Application of IRB floor

How should the IRB floor requirement, stemming from Article 500 CRR (transitory Basel I floor), be applied in case of an IRB institution that uses standardised method (after regulator’s approval) as an alternative to Basel I floor in the situation when 80 % of the total minimum amount of own funds calculated under standardised method (SA) is higher than the own funds calculated under IRB approach?Is the institution in such circumstances obliged to recognise an additional capital (own fund) requirement, resulting from the difference between the floor value based on STA and the actual own funds calculated under IRB capital requirements, directly in its capital adequacy ratio (the positive difference between 80% of STA RWA and IRB RWA to be added to denominator of capital adequacy ratio calculation)?Or rather the IRB bank is only obliged to ensure that it holds own funds at the level which is more or equal to the 80% of the total minimum amount of own funds as required under Basel I (or STA under Basel II, after regulator’s approval), i.e. the level of own funds is sufficient for covering the IRB floor requirement of Art. 500 CRR?

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

Deduction of deferred tax assets

Does the CRR recognise any form of deferred tax assets (DTAs) that do not rely on future profitability, other than those specified in Article 39(2) of the CRR?

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

Deduction of deferred tax assets

Regarding the phasing-in percentages established in Article 478(2) of the CRR, how should the deduction amount  be calculated during the transitional period when part of the stock of DTAs existed prior to 1 January 2014?

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

Supervisory Benchmarking - Alternative risk weight

How shall mortgage portfolios for which - based on Art. 230 (3) CRR when the conditions of Art. 199 (6) CRR are satisfied - an alternative risk weight (e.g. 50% for commercial real estate) is used, be reported in the benchmarking exercise. Or should these exposures where no PD or LGD estimation is available for regulatory purposes be exempted from the reporting.

  • 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)

Undrawn uncommitted credit lines

What do we understand with "Undrawn uncommitted credit lines"? Are uncommited credit lines in the scope of the benchmarking? What kind of products are we talking about that fall into this category of facilities - are we talking about internal lines that have not been communicated to the customer? Are these relevant for COREP and the supervisory benchmarking?

  • 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)

Validation Rule v3748_s partly incorrect

According to COMMISSION IMPLEMENTING REGULATION (EU) 2016/1702 of 18 August 2016 column 430 of Template ‘C 13.00 — CREDIT RISK – SECURITISATIONS (CR SEC IRB)’ has to be reported with negative values.Description: ‘ADJUSTMENT TO THE RISK-WEIGHTED EXPOSURE AMOUNT DUE TO MATURITY MISMATCHES: For maturity mismatches in synthetic securitisations RW*-RW(SP), as defined in Article 250 of CRR, shall be included, except in the case of tranches subject to a risk weighting of 1 250 % where the amount to be reported is zero. Note that RW(SP) not only includes the risk weighted exposure amounts reported under column 400 but also the risk weighted exposure amounts corresponding to exposures redistributed via outflows to other templates. Negative values shall be reported in this column.’Therefore column 430 should be excluded from validation Rule v3748_s.

  • 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)