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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

Credit claims in liquidity stress test buffer

Are credit claims eligible for the liquidity buffer (counterbalancing capacity) if they are not already pledged with the central bank? In particular, would the credit claims originally intended for covered bonds form part of the bank’s pool of collateral for monetary policy credit operations before they become eligible for the counterbalancing capacity (CBC)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2003
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as final Q&A: 13/04/2018

Liquid assets under CRR/LCR

The primary question is how to consider the relation between CRR and LCR, i.e. shall the liquid assets under LCR be interpreted in accordance with the liquid assets definition under CRR? Provided that the answer is positive, how does this affect a see-through of a CIU that only partially consists of assets that are liquid under CRR? Under said circumstances, is there a risk that the non-liquid assets will contaminate the CIU as a whole, or is it possible that the share of the assets that is liquid can be covered by 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: 2015_2002
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Credit risk - standardised approach

Can cash equivalents be assigned a Risk weight of 0%? What is the definition of an equivalent cash item?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2001
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 13/11/2015

Row asset-backed securities in Asset encumbrance templates

Can you please make the row 060 'asset-backed securities' in table F 32.01 consistent with the Annex XVII (reporting on asset encumbrance) page 10 'of which: securitisations'? Same applies to row 180 in F 32.02.

  • 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: 2015_1999
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of exposures with immovable property as collateral

A bank has its head office in one EU country and has a branch in Luxembourg. Both the head office and the branch are required to submit separately template C15. The Luxembourg branch submits in Luxembourg template C15 with the branch information only. According to Annex VII of the Commission Implementing Regulation (EU) No 680/2014. The exposures to be reported in template C15 relate to exposures whose collateral (immovable property) is used to reduce regulatory own fund requirements. The head office and the Luxembourg branch have some loans secured by immovable property in various countries. However, the immovable property is not used either at the head office or at the Luxembourg branch for reducing regulatory own fund requirements. Therefore, our understanding is that neither the head office nor the Luxembourg branch should report these exposures in C15 template. We would like to confirm this approach following the request of the national competent authority given that there are no separate capital requirements at the Luxembourg branch level.

  • 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: 2015_1996
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Definition of undrawn committed credit facilities to report

Can you please clarify, why only those undrawn committed credit facilities shall be reported in template C60 (row 1320), which have a maturity <= 3months? 

  • 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: 2015_1994
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Change of minimum values of exposure weighted average LGD for exposures secured by property in their territory

Does Article 164(5) of Regulation (EU) No 575/2013 (CRR) allow competent authorities to set higher minimum values of exposure weighted average LGD for exposures in one or more parts of its territory on the basis of Financial stability considerations? (In the same way as it is possible under Article 124(2) CRR)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1992
  • Topic: Credit risk
  • Date of submission:

Can third country insurance companies be considered as unregulated financial entities

If a third country insurance or re-insurance is considered as not subject to "prudential supervisory and regulation requirements at least equivalent to those applied in the union" (as stated in article 142 (4) ) should we definitely consider this entity as neither "large financial sector entity" neither "unregulated financial sector entity" as defined under article 142 (4) and (5) ? Indeed the definition of "unregulated financial sector entity" ("an entity that is not a regulated financial sector entity but that performs, as its main business, one or more of the activities listed in annex I to directive 2013/36/EU or in annex I to directive 2004/36/EC") does not cover insurance activities.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1991
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/02/2017

Third country equivalent large financial sector entities

If the Implementing Act of the EU has stated equivalent third countries for investment firms, exchange and credit institution there is no such a list for insurance and re-insurance companies.Nevertheless, if we understand that CRR contains no list of equivalent countries for insurance and re-insurance companies, or no recommendations on EBA to produce such a list, institutions need clear guidelines if they want to correctly apply article 142 (4) of CRR.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1989
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/02/2017

Treatment of assets held at a central bank to provide intra-day collateral for supporting payment flows in a direct payment system for the calculation of end-of-day and reporting of assets available for High Quality Liquid Assets (HQLA)

Are assets held in an account opened at a central bank for the purposes of providing intra-day collateral for the purposes of supporting payment flows in a direct payment system, to be treated as “unencumbered” for the purposes of end-of-day calculating and reporting of assets available for High Quality Liquid Assets (HQLA) under Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement?Where assets are held in an account opened at a central bank for the purposes of providing intra-day collateral in connection with the provision of funding for settlement activity, at end of the day should such assets be treated as “unencumbered” for the purposes of calculating and reporting assets available for HQLA? And are in this context the provisions of Article 7(2)(a) of DR (EU) 2015/61 applicable?

  • 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: 2015_1987
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of disputed margin call under Article 285(4)

What is the relevant definition of margin call dispute for the purpose of doubling the margin period of risk, under Article 285(4), for netting sets which have experienced a material number of extended disputes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1986
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/11/2015

Clarification of disclosure requirement for severance

Article 450(1)(h)(v) and Article 450(1)(h)(vi) both refer to severance; (v) asks for severance payments made during the financial year and (vi) asks for severance payments awarded during the financial year. Are these one and the same?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1985
  • Topic: Transparency and Pillar 3
  • Date of submission:

Klärung: Emissionsvolumen bei Covered Bonds € 500 Mio. (oder den Gegenwert in Landeswährung) / EN TRANSLATION: Clarification: 'the issue size of the covered bonds is EUR 500 million (or the equivalent amount in domestic currency)'

1) Bezieht sich das „Emissionsvolumen“ auf die Erstemission der Schuldverschreibung oder das Emissionsvolumen insgesamt (einschließlich aller späteren Emissionen der Schuldverschreibung), d. h. das Gesamtemissionsvolumen? 2) Bezieht sich der „Gegenwert in Landeswährung“ auf den Betrag zum Zeitpunkt der Emission oder den anhand des aktuellen Wechselkurses berechneten Betrag? EN TRANSLATION: 1) Does the "issue size" refer to the initial bond issue or the total issued volume (including subsequent bond issues), i.e. the total issue size? 2) Does "the equivalent amount in domestic currency" mean the amount at the time of issue or calculated using the current exchange rate?

  • 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: 2015_1976
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 18/03/2016

CVA Risk Charge Calculation for derivatives in the banking book with local GAAP

Do institutions that use local GAAP for accounting purposes and do not mark-to-market derivatives in the banking book have to calculate a CVA Risk Charge for derivatives in the banking book?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1975
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/11/2015

“Direct” control

In the example stipulated in the background section, does Central Government A - even if it does not hold the voting rights over company B1 directly by itself - exercise "direct" control over B1 within the meaning of Article 4 (1) (39) last subparagraph CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1974
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 24/06/2016

Funding plan for credit institutions: meaning of "maturing gros outflow"

regarding to table P01.02 row 200, the definitional reference states "Instruments of this type which are contractually due to mature during the time from the end of the previous period to the relevant period-end".

  • 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
  • ID: 2015_1969
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Exposure to third country institutions and investment firms

What is the treatment for credit risk purposes of an exposure to an investment firm which is established in that third country and which is subject to the supervisory and regulatory requirements applicable to credit institutions in that country?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1968
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/04/2015

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
  • ID: 2015_1963
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

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
  • ID: 2015_1962
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 09/11/2018

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)
  • ID: 2015_1960
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017