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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

C 08.01 - validation rule v5739_h (applicable as of v2.7)

According to validation rule v5739_h, the value in row 010 (“Total exposures”) should be >= the value in row 015 (“Exposures subject to SME-supporting factor”). We think this rule is only relevant for columns which report amounts and not for columns which report averages, such as column 250 (exposure-weighted average maturity value). Can this validation rule be corrected and not be applied to column 250 anymore?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2018_3774
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Clarification of the requirement to establish concentration limits on liquidity providers and establish at least two arrangements for each major currency.

In conjunction with REGULATION (EU) No 909/2014 Article 59(4)(e), does Regulation (EU) 2017/390 Article 38(5) stipulate a requirement to have at least two arrangements in place in each major currency to convert collateral or assets into cash using prearranged and highly reliable funding only? Does the requirement to establish concentration limits and to have at least two arrangements in place include alternative liquidity arrangements such as committed unsecured lines of credit or committed FX swap facilities?

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2018_3773
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule v5548_h (FINREP template F 11.01 IFRS 9)

The validation rule v5548_h requires for template F 11.01 FINREP for all columns (010/020/030/040) row 460 (Cash flow hedges needs to be >= row 480 (Portfolio Fair value hedges of interest rate risk). Both amounts are part of the Derivatives Hedge accounting but there is no link between row 460 and 480. Can you delete validation rule v5548_h?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3770
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Interpretation of the term ‘ancillary services undertaking’ as defined in point (18) of Article 4 (1) CRR with a view to ‘intermediary undertakings’

Does the term ‘ancillary services undertaking’ as defined in point (18) of Article 4 (1) CRR include undertakings that act as an intermediary of business activities (‘intermediary undertakings’ or ‘brokers’), where those business activities themselves would lead to the qualification as an ‘institution’ as referred to in point (3) or a ‘financial institution’ as referred to in point (26) of Article 4 (1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3769
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Exposures to unrated institutions

How should exposures to unrated institutions be treated under Article 121 CRR in the cases where these institutions are located in a Member State or in a third country that does apply supervisory and regulatory arrangements at least equivalent to those applied in the Union and the exposures to the central government and central bank denominated and funded in domestic currency are assigned a risk weight according to Articles 114(4) to (7)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3765
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Reporting of memorandum items behavioural outflow/inflow in the ALMM maturity ladder (C 66.01)

The instructions on memorandum items behavioural outflow/inflow state to redistribute the amounts in items 1.3 (deposits) and 2.2 (loans). Does this mean that the total amount of notional and interest cash flows according to contractual agreements are redistributed across the time buckets? In other words, is it expected that the total amount in column 020 till 220 of row 17 (and 18) equal the total amount in column 020 till 220 of row 1.3 (and 2.2)? 

  • 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: 2018_3763
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Definition of a qualifying holding

In order to identify a qualifying holding in an undertaking, for the purposes of the definition laid down in Article 4(1)(36) CRR, has the possibility to exercise a significant influence over the management of an undertaking to be accompanied, as a necessary precondition, by an even minimum level of holding in that undertaking (as suggested by the English or Italian language version of CRR)? Or, conversely, can the definition of qualifying holding in Article 4(1)(36) CRR be met, in cases where the possibility for a person to exercise a significant influence in an undertaking is established, even in the absence of a minimum level of holding in the undertaking by that person?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3762
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 03/05/2019

Transposition of Article 96

Should the national provisions which are going to transpose Article 96 only provide for the resolution of branches of a third-country institution located in the same Member State?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3757
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Application of margin period of risk scalars for exposures to clients

Do the provisions laid out in Article 304(3)(a), Article 304(4) and Article 304(5) of the CRR, also apply to the calculation of the EAD for leverage ratio purposes?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2018_3756
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/03/2019

Column 100 of the C 25.00 - CVA RISK template

Should OTC derivatives counterparties that have Zero EAD and hence Zero CVA charge be included in the count of counterparties required to be reported in template C 25.00, column 100.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3754
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Risk weighted assets calculation under Article 119(2) of the CRR

What would be the applicable risk weight according to Article 119 (2) of Regulation (EU) No 575/2013 (CRR), to an exposure in the scope of Article 114(6)(a) CRR? 

  • 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: 2018_3753
  • Topic: Credit risk
  • Date of submission:

How to report data in c230 and c240 of C 07.00

In EBA /ITS/2017/01 published 07 April 2017, c230 and c240 of C 07.00 are sub categories of c220. If the RW applied is based on uniform treatment paragraphs rather than an ECAI e.g. Article 119(2) of Regulation (EU) No 575/2013 (CRR) , should these RWA be included in column 230 & 240 of COREP C 07.00 even if they do have an own ECAI or could have applied the sovereign rating. e.g We have an exposure of 1000 in GBP to a Regional Government incorporated in UK for which a 20% RW is applied according to Article 115 (5) of the CRR. Additionally this exposure could attract a 20% RW by applying the sovereign rating. Based on the example do we include the RWAs of 200 GBP in column 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)
  • ID: 2018_3748
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Realization of developers' collaterals and re-classification of developers into performing status

Clarifications are requested surrounding the classification of a borrower into default status and therefore into non-performing status, when the borrower is a developer / construction company and hence relies on the realisation of collaterals to repay his loans.

  • 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: 2018_3747
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of cash flows related to collateral management transactions in which collateral to be delivered/received is defined using the participants netting exposure

If a credit institution has two repo/reverse repo trades of the same size, same basket, different positions and different maturities (one within 30 days and the latter maturing after 30 days horizon) with a CCP which requires for collateral exchange on a net basis, how should these operations be represented in 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: 2018_3745
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Reporting of forward starting transactions

Annex XXV Reporting on Liquidity Coverage Ratio defines remarks regarding settlement and forward starting transactions. The only forward starting transactions taken into consideration are forward repos, forward reverse repos and forward collateral swaps that start and mature within the LCR’s 30 day horizon and that are entered into subsequent before the reporting date. The Q&A 2014_784 published in 2014 seemed to identify a wider definition of relevant forward transactions for the LCR than the Annex XXV does some time after.  Should we limit our definition to Annex XXV one, or other forward start transactions are relevant for LCR if these two conditions are valid: •         are contractually fixed, but not yet settled at reporting date; and •            imply an in- and/or outflow of cash and/or liquid assets in the next 30 days? In this case, how should we report forward starting purchase or own issuance? If contractually fixed, forward starting transactions generating inflows or outflows are treated symmetrically for LCR or Article 32 par 7 introduces asymmetry?

  • 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: 2018_3744
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting of Assets received as collateral in GC pooling transactions

When a financial instrument is received as collateral in a GC pooling transactions which allows participants to refinance the collateral through transactions with Central Bank or with other transactions in the same market, is the above-mentioned financial instrument eligible for the liquidity buffer under Article 7 LCR DA conditions?

  • 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: 2018_3741
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Reporting of template C17.01

1) Should all loss adjustments regardless of the Date of Occurrence of the original loss event be reported?2) For the rows relating to "Loss adjustments relating to previous reporting periods" (rows x40), should the adjustments be subject to materiality thresholds? Can the threshold used for registration of losses be applied also to loss adjustments?3) How should grouped losses split across multiple business lines be reported on row 910 "Number of events (new events)"? In case the loss is reported on multiple business lines, the row 910 will be lower than the sum of loss events reported on individual business lines.

  • 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: 2018_3740
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Location of the obligor for the calculation of the countercyclical capital buffer

What is the definition of “actual place of administration” in Article 1(4) of Regulation (EU) 1152/2014?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1152/2014 - RTS on the identification of the geographical location of relevant credit exposures for institution-specific countercyclical capital buffer rate
  • ID: 2018_3739
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 11/10/2019

SCV file test requirements by 3 July 2019

Does "formal routine checks" of SCV files in Article 96 refer to all indicators in paragraph 70 i1-i4? If so, are DGSs required to test all indicators by sampling files from all affiliated credit institutions by 3 July 2019?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/10 - Revised Guidelines on stress tests of deposit guarantee schemes under DGSD (repealing and replacing EBA/GL/2016/04)
  • ID: 2018_3738
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 27/07/2018