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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

Client money

To what extent the deposits linked to securities accounts can be qualified of “client money”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1826
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Client money

To what extent the cash held by a UCITS can be qualified as client money?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1825
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 24/07/2015

Netting of Derivatives

In the Article 45b(6), first subparagraph, Directive 2014/59/EU (BRRD) specifies that "derivative liabilities shall be included in total liabilities on the basis that full recognition is given to counterparty netting rights". What are the netting principles applicable? Does the Article 45b(6), first subparagraph, of the BRRD refer to accounting or prudential netting principles?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1824
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 10/06/2016

Asset Encumbrance & Covered Bonds

Are assets in cover pools that are not necessary to fulfil regulatory requirements deemed to be encumbered for Parts A, B, C and E of the Asset Encumbrance Reporting templates?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1817
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 25/09/2015

Reduction of CET1 by absorbing losses which are already accounted as loss brought forward

Is the prior permission of the supervisor required when an institution reduces its CET1 instruments by absorbing losses which were already accounted for as retained losses (i.e. loss brought forward)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1815
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 05/06/2015

Clarification of the treatment of positions in commodities for the purposes of calculating net and gross position according to Article 360(1) of Regulation (EU) No 575/2013 (CRR)

Should long and short positions in the same commodity (or the same derivative based on the commodity) be netted against each other in the first place and then the net and gross positions should be calculated taking into account positions in other derivatives with the same commodity as the underlying instrument?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1813
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 25/09/2015

Treatment of equity, equity index and commodity futures/forward contracts under Part three, Title IV of Regulation (EU) No 575/2013 (CRR)

Shall equity, equity index and commodity futures/forward contracts be treated as exposure in an underlying instrument or should they be treated as combination of long and short position (holding of the underlying and borrowing maturing on the delivery date of the futures/forward contract)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1812
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/11/2015

Applicable exposure class for exposures to institutions based in a third country that does not apply prudential supervisory and regulatory requirements

For those institutions based in a third country that does not apply prudential supervisory and regulatory requirements at least equivalent to those applied in the Union, should the exposure class to these institutions be disclosed as an exposure to corporate or exposure to institution? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1806
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of overdue factoring contracts

In the case of trade finance (factoring) contract with multiple accounts receivable (corresponding multiple debtors) of which only single one is past due, should the carrying amount be reported (in the table F 07.00 Financial assets subject to impairment that are past due or impaired) at the single debtor (single account receivable) level that is actually past due or general contract level? Should it be differently reported in the case of factoring contract with the recourse right and without the recourse right?

  • 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_1804
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

C69.00 – Time-periods covered by column set

What are the intended time periods for the columns “Spread” and “Volume” in template C69.00 – Prices for Various Lengths of Funding?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1802
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Validation Rule v3688_s (Blocking Rule)

The validation rule does not seem correct as the 'Adjustments to total own funds' (Template C 04.00, column 010, row 870) could also be of a negative value.

  • 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_1801
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Treatment of an asset entitled 'Rent Deposit'

Should an asset of a 'rent deposit' held in the current assets of a company's balance sheet be treated as encumbered or unencumbered? If it is to be included as encumbered should the fair value of the encumbrance be the amount of the entire contract that the rental deposit secures?

  • 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_1800
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/06/2021

Intra-group financial support with regard to third countries

Why does Article 19 (1) of Directive No 2014/59/EU (BRRD) include third countries and how is the procedure of granting intra-group financial support supposed to work regarding third countries?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1799
  • Topic: Intra-group financial support
  • Date of submission:
  • Published as final Q&A: 06/02/2015

Use of the resolution fund

Are the purposes for which a resolution fund can be used exhaustive according to Article 101 of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1797
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 06/02/2015

Resolution action with regard to a holding

When can a resolution action be taken with regard to a holding according to Article 33(4) of Directive 2014/59/EU (BRRD): are the conditions individual or cumulative?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1796
  • Topic: Resolution objectives and triggers
  • Date of submission:

De Minimis and weighting for foreign exchange risk

Should the own fund requirement of foreign-currency option non-delta risk be calculated by all institutions, or only if the net open FX position is greater than 2%?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 528/2014 - RTS on non-delta risk of options in the standardised market risk approach
  • ID: 2015_1795
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/07/2015

Meaning of "initial" recovery plan

What does the reference to the ‘initial’ recovery plan’ in Article 27(1)(a) of Directive 2014/59/EU (BRRD) mean? Is it the first recovery plan or does it relate to subsequent recovery plans?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1794
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 06/02/2015

Differences between proportionality in the CRD IV and Simplified obligations in the BRRD.

In accordance with the Directive 2014/59/EU (BRRD), Article 74(4) of CRD IV will expire when BRRD is implemented. Is the proportionality in the CRD IV different from the simplified obligations in the BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1793
  • Topic: Interactions with the CRR / CRD IV and the BRRD
  • Date of submission:
  • Published as final Q&A: 06/02/2015

Recognition of additional credit protection in the regulatory LGD

It is not clear whether an institution with an IRB Approach permission (Foundation Approach; PD models only) should notify the competent authorities in accordance with Article 143 if they want to recognise additional credit protection in the regulatory LGD in accordance with Article 161(1).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2015_1792
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/06/2015

Market making prior to 5 years from issuance of AT1-/T2-Instruments – follow up of Q&A 2013_290

In the case of a repurchase of own funds instruments for market making pur-poses, competent authorities may give their permission in advance in order to reduce own funds for a certain predetermined amount within the limits laid down in Article 29(3) of Regulation (EU) No 241/2014 (RTS on own funds part 1 and 2). However, the RTS does not specify when market making can take place. Thus, clarification is sought whether repurchases for market making purposes are permissible before five years after the date of issuance provided that the conditions stipulated by the RTS are met.

  • 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_1791
  • Topic: Own funds
  • Date of submission: