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List of Q&A's

Treatment of existing Tier 1 and Tier 2 instruments

This question is a supplement to Question 2013_46. For Tier 1 or Tier 2 instruments with an incentive to redeem and quarterly/semi-annual/annual calls beyond the first call date, would these instruments qualify as Tier 2 capital if the issuer gave an undertaking to its regulator and the market that it would not exercise its call option for at least 5 years after the first call date? This would save the issuer the time and expense of having to modify the actual instrument documentation but would achieve a similar outcome in terms of its capital position/quality.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_105
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 13/12/2013

Information to be declared under the concept of "discretionary pension benefits" in the annex of EBA/GL/2012/5 and in annex 2 of EBA/GL/2012/4

(1) What is the information to be declared by institutions under the concept of “total discretionary pension benefits” established in the annex 1  of EBA/GL/2014/07? A. Contributions made, during the year, by the credit institution to the company’s pension scheme, on behalf of the employee as part of their variable remuneration, or B. Amounts to be paid, or already satisfied, by the credit institution to the employees who have left the institution or got retired during the year. (2) What is the information to be declared by institutions under the concept of “total discretionary pension benefits” established in the annex 2 of EBA/GL/2014/08? A. Contributions made, during the year, by the credit institution to the company’s pension scheme, on behalf of the employee as part of their variable remuneration, or B. Amounts to be paid, or already satisfied, by the credit institution to the employees who have left the institution or retired during the year.  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_103
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/11/2013

COREP: Validation rules on draft ITS for C19.00 (MKR SA SEC)

In this return (C 19.00 MKR SA SEC) we are asked to complete the average risk weight (%) for securitisations going through the supervisory formula approach and the internal assessment approach, in columns 260, 290, 490 and 520. The validation rules in Annex XV specify that these % figures are simply added together, as for any other columns on the return. This produces a mathematically nonsensical result. For example, for the total row (row 010) we should add together the average % amounts from each securitisation category, to reach a total average %. The total is thus the sum of the average %s of each row, a figure that owes more to how many rows are being completed than to any particular value. % Would it not be more mathematically sensible to take the average % of the total? In other words, to replace the existing {r010,c260} = {r030,c260} + {r060,c260} + {r090,c260} with {r010,c260} = {{r030,c260} * {r030,c250}} + {{r060,c260} * {r060,c250}} + {{r090,c260} * {r090,c250}} ? Or if this is not suitable, to not calculate the value at all?

  • 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: 2013_102
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

IRB exposure value - Recognition of specific credit risk adjustment for positions measured at fair-value (e.g. IFRS category FVO, HfT and AfS)

Which is the exposure value according to Article 166 (1) of Regulation (EU) No. 575/2013 (CRR) for IRB positions measured at fair value (to p+l or OCI) in the relevant accounting standard, when a separation of credit risk and market risk related fair value changes (e.g. revaluation reserve) for these positions is not possible and therefore not used to cover expected loss in accordance with Article 159 of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_101
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 14/03/2014

Exclusion of provisioned counterparties from the CVA capital charge

Could you confirm that a defaulted or doubtful counterparty that is subject to specific provisions/cost of risk shall not be subject to the CVA capital charge?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_99
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/11/2013

FINREP - Contents of template 41.2 Use of the fair value - Crossing col 030 "Hybrid contracts" / Row 020 "equity instruments"

FINREP Template 41.2 Use of the fair value - Crossing col 030 "Hybrid contracts" / Row 020 "equity instruments" : this crossing is forbidden ; even if few cases are expected, how do we have to report possible occurrences ?

  • 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: 2013_97
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of template 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount"

FINREP - Template 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount" : for entities with a different accounting treatment under IFRS Group scope and under CRR Group scope, the amount related to which scope is expected ?

  • 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: 2013_96
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of template 40.1 Group structure "entity-by-entity" - Col 080 "Profit or (-) loss of investee"

FINREP - Template 40.1 Group structure "entity-by-entity" - Col 080 "Profit or (-) loss of investee" : which result is expected in column 080 : "profit or loss for the period" or "total comprehensive income for the period" ?

  • 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: 2013_95
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

Applicable risk weights for agricultural properties.

Should exposures fully secured by agricultural properties be assigned a risk weight of 100% according to article 124 or can they be considered as residential or commercial properties according to article 125 and 126 and, thus, have a lower risk weight?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_94
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 27/08/2013

FINREP - Contents of template 40.2 Group structure "instrument-by-instrument"

FINREP - Contents of template 40.2 Group structure "instrument-by-instrument" : we don't understand the scope of templates 40.2 : do we have to report all securities in our portfolio issued by an entity included in our accounting scope ? The amounts expected in columns 030 to 050 (holding company) are related to the security or to the holding company ? We need further explanations"

  • 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: 2013_93
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope

FINREP - Template 40 Group structure (40.1 "entity-by-entity" - 40.2 "instrument-by-instrument") - Notion of Group scope : we understand that the scope to be considered for the templates 40.1 and 40.2 is the Accounting Group (including insurance companies for example) and not the CRR Group (excluding insurance company for example). Can you confirm this point ?

  • 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: 2013_92
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" et Column 050 "other related parties"

FINREP - Template 31.1 Related parties: amounts payable to and amounts receivable from (+ template 31.2) - Column 020 "subsidiaries" and Column 050 "other related parties" : can you confirm that the column 020 "subsidiaries" includes transactions with "sister entities" ?

  • 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: 2013_91
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]"

FINREP - Template 22.1 Fee and commission income and expenses by activity (+ template 22.2) - Row 140 "Customer resources distributed but not managed [by type of product]" : for this row, the ITS refers to "products issued by entities outside the Group" -> Which level of Group has to be considered : Accounting Group (including insurance companies for example) or CRR Group (excluding insurance companies for example) ?

  • 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: 2013_90
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts"

FINREP - Contents of template 17.3 Reconciliation between Accounting and CRR scope of consolidation - Liabilities and equity - Row 170 "Liabilities under insurance and reinsurance contracts" : does the row 170 "liabilities under insurance and reinsurance contracts" include insurance company technical reserves?

  • 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: 2013_89
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Contents of template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets"

FINREP - Template 16.7 Impairment on financial and non-financial assets - Cancellation of the row 150 "impairment of other non-financial assets" : on which row do we have to set amounts linked to "other non financial assets" and reported on row 570 "other" in template 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: 2013_88
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - F16.7 Impairment on financial and non-financial assets - "Impairment or (-) reversal of impairment of investments in subsidaries, joint ventures and associates" (Rows 070 à 090)

FINREP - Template 16.7 Impairment on financial and non-financial assets - "Impairment or (-) reversal of impairment of investments in subsidaries, joint ventures and associates" (Rows 070 à 090) : in spite of the reference to IAS 28, we presume that the row 080 "joint ventures" anticipates IFRS 11 (with the end of proportionally consolidation). But we don't understand what is expected on the row 070 "subsidiaries" : these one are all fully consolidated and not with the equity method.

  • 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: 2013_87
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - Template 16.1 Interest income and expenses by instrument and counterparty sector (+ template 2) - Setting of interests on derivatives - hedge accounting other than interest rate risk

FINREP - Template 16.1 Interest income and expenses by instrument and counterparty sector (+ template 2) - Setting of interests on derivatives - hedge accounting other than interest rate risk : concerning interest on derivatives held for hedge accounting other than interest rate risk, we wonder about their setting: - we understand they are not included in template 16.1 ; can you confirm this point ? - on which row of template 2 "statement of profit or loss" should they be included ? We foresee to include them on row "other assets" (row 080) and "other liabilities" (row 140). Is it correct?

  • 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: 2013_86
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: F14 Fair value hierarchy: financial instruments at fair value - Columns 060 to 080 "Accumulated change in fair value before taxes"

FINREP - Contents of template 14 Fair value hierarchy: financial instruments at fair value - Columns 060 to 080 "Accumulated change in fair value before taxes" : do gains and losses to be reported in columns 060 to 080 include only gains and losses accounted in the statement of profit or loss (like columns 040 and 050) or do they also include gains and losses accounted in "statement of comprehensive statement" ?

  • 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: 2013_85
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP - F13.1 Breakdown of loans and advances by collateral and guarantees - Col 030 "Other collateralized loans - Cash [Debt instruments issued]"

FINREP - Template 13.1 Breakdown of loans and advances by collateral and guarantees - Col 030 "Other collateralized loans - Cash [Debt instruments issued]" : ITS 81b indicates that Column 030 includes "pledges of debt securities issued by the institution". We don't understand the reference to "debts securities issued by the institution" : an institution secure its loans with securities issued by other issuers but not with its own securities; moreover, CRR Article 197 is referring to debt securities issued by different issuers but not to debt securities issued by the institution. Can you explain this?

  • 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: 2013_84
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014

FINREP: F12 Movements in allowances for credit losses and impairment of equity instruments - Col 020 to 060 - Breakdown by counterparty

FINREP - Template 12 Movements in allowances for credit losses and impairment of equity instruments - Col 020 to 060 - Breakdown by counterparty : the breakdown by counterparty of "variation flows" columns (columns 020 to 060) is heavy - does EBA allow that institutions make this breakdown only on "closing balance" column (col 070) as it tolerates for similar template FIN 30B in current FINREP?

  • 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: 2013_83
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2014