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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

SME supporting factor

Can you please confirm whether the SME supporting factor can be applied to derivative exposure and Repo exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1050
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Country of transaction, scope of disclosures and intragroup transactions

It is expected that transactions will be attributed to the country of the unit of the group that is party to the transaction. How should intra-group cross-border transactions and consolidation adjustments be treated? How should the impact of associates and joint ventures on the reported figures be dealt with?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1045
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 19/12/2014

Location of disclosures and audit consequences

Should or could the country-by-country reporting requirements be included in the notes to the financial statements, which represent an inherent part of these statements, or does the requirement ask to design a new separate annex to the financial statements?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1044
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 19/12/2014

Definitions of reportable items

The disclosure requirements use terms which need to be defined to ensure consistency of disclosures provided by institutions and audited by their auditors. In this context we seek clarification concerning tax as referred to in Article 89(1)(d) and (e) of Directive 2013/36/EU (CRD). Does it contain only current tax expense or also deferred tax? If deferred tax is included, does it comprise only the profit or loss element, or also changes in deferred tax recognised in other comprehensive income? Alternatively, should it include only the tax cash-flows made in the relevant period?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1043
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 19/12/2014

Currency in which the information that the institutions report to the competent authorities of the home member State must be submitted, according to art. 415, par.2. (Templates: C.51.00.w, C.51.00.x, C.52.00.w, C.52.00.x, C.52.00.y, C.52.00.z, C.53.00.w, C.53.00.x, C.53.00.y, C.54.00.a, C54.00.w)

In order to ensure uniform reporting among all entities of LCR and NSFR templates, the following question has arisen: which is the currency in which the information dealing with the significant currencies must be reported according to article 415.2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1042
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 29/05/2015

Reporting RMBS issued by SSPEs in C51.

Can the EBA confirm that our understanding is that RMBS that according to Basel III are classified as Level 2B assets and are CB eligble should be reported in C51. ID 1.11.1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2014_1041
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Treatment of Cash collateral

How does cash collateral be treated as this creates a financial asset when cash collateral has been given for initial margin or adverse margin. Does this form part of the other assets section of the return, or is it excluded? If it is to be included, should it be unencumbered?

  • 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: 2014_1039
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Risk weighted exposures of CET1 holdings in financial sector entities which are not deducted from the institution's CET1 capital

ITS instructions for Annex I, C04.00, r650, c010 refer to article 46.4 that only deals with non significant investments in financial sector entities. Heading of reporting line seem to indicate that all the holdings (be significant or not) in financial sector entities should be reported there if not deducted from own funds. Can you clarify?

  • 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: 2014_1037
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Transferred financial assets, Template 15, validation rules for column 10

Assume a scenario where an institution has long and short positions for the same CUSIP and presents a net asset on the face of its IFRS balance sheet (and, similarly, in FINREP template 1.1). In the situation where the long position serves as a collateral under institution’s Repo obligation, what amounts shall be reported in Template 15 column 10 – amount of long position that is associated with Repo obligation or a net asset for this CUSIP (i.e. the difference between long and short position) as reported on the face of balance sheet (Template 1.1)? If long positions are to be reported, do the implications of the validation rules v0897_m - v0909_m for Template 15, column 10 lead to reporting a number different from that intended?

  • 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: 2014_1032
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Forborne exposures, Template 19, column 110

Column 110 of Template 19 provides references to Annex V.Part 2.157 and Annex V.Part 2.172(a). Our understanding is that this column requires disclosure of exposures with forbearance measures, that would otherwise be classified as performing but have not met all of the additional exit criteria extended to non-performing exposures with forbearance measures as defined in Annex V.Part 2.157 (e.g., the exposure is no longer classified as defaulted or impaired and there are no past due amounts, but only 8 months have passed since forbearance measures were extended and therefore it should remain to be classified as non-performing). We believe that the intent is to show those exposures that are performing better after the forbearance measures were extended and would be classified as performing if there were no additional exit criteria set out by Annex V.Part 2.157. Can you please confirm if this is a valid interpretation or different information is required to be reported in this column?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1031
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Requisito minimo Basilea 1 / Basel 1 minimum requirement

L'art. 500, comma 1 b) del regolamento 575/2013 richiede che i Fondi Propri (Common Equity Tier 1 + Additional Tier1 + Tier 2) siano sempre pari o superiori all'80% del Requisiti Patrimoniali Minimi Basilea 1 (REQBIS1). Inoltre, l'art 500 comma 4, richiede che i Fondi Propri siano integralmente corretti in modo da riflettere il differente trattamento delle perdite attese ed inattese ( Shortfall IRB , Excess IRB) , ma non indica una modalità di calcolo. Si richiede se l'approccio seguente sia corretto: 80% * REQBIS1 >= (Common Equity Tier 1 + Additional Tier1 + Tier2) + |Shortfall IRB| - |Excess IRB|. EN TRANSLATION Article 500(1)(b) of Regulation (EU) No 575/2013 requires that own funds (Common Equity Tier 1 + Additional Tier 1 + Tier 2) are at all times more than or equal to 80% of the minimum capital requirements of Basel I (REQBIS1). In addition, Article 500(4) requires that own funds shall be fully adjusted to reflect the separate treatments of expected loss and unexpected loss (Shortfall IRB, Excess IRB), but does not indicate a method of calculation. Is the following approach correct? 80% * REQBIS1 <= (Common Equity Tier 1 + Additional Tier1 + Tier2) + |Shortfall IRB| - |Excess IRB|.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1030
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 14/11/2014

Template 43 Provisions, columns 040 and 060

In the UK, banks currently have a number of customer redress provisions. These are provisions to return customers to the financial position they would have been in if they hadn't been unfairly disadvantaged by past banking practices. Determining whether customers have been unfairly disadvantaged and are thus due redress is overseen by the conduct regulator in the UK, the FCA. As well as this, all individual cases can be arbitrated if necessary by a consumer protection body, the Financial Ombudsman Service. In terms of who obliges the banks to pay out redress, it is these regulatory bodies. Their authority derives from legislation. Conversely, banks have established constructive obligations (in IAS 37 terms) to pay redress to their customers by industry practice, and by the communications they have sent to those customers. Looking at template 43, there is no column in the template for provisions arising from regulatory obligations, so we believe we have to choose between classifying these provisions in 040 "Pending Legal Issues and Tax Litigation", or 060 "Other Provisions". We believe that it is possible to consider these regulatory obligations as either "Pending Legal Issues and Tax Litigation" given the IAS 37 definition of "legal obligation" implied by the template, or conversely as "Other Provisions" because of the constructive obligations in effect.

  • 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: 2014_1027
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Issues with Template row headers

On Template C_16.00.b header row 'Subject to ASA' has been numbered on XBRL template as row 125 and inserted above row 130. Header row 'Subject to ASA' should appear on XBRL template C_16.00a above row 110

  • 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: 2014_1025
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Header in Template C_09.02 has incorrect wording

The header for column 125 in Template C.09.02 reads: RISK WEIGHTED EXPOSURE AMOUNT PRE AFTER SME-SUPPORTING FACTOR The correct heading is: RISK WEIGHTED EXPOSURE AMOUNT AFTER SME-SUPPORTING FACTOR

  • 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: 2014_1024
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

The mortgage lending value of the German property

The part of an exposure treated as fully secured by a German property shall be the lower amount of the market value or the mortgage lending value of the property. Does it mean that the mortgage lending value of the German property must be determined so that the property can be treated as collateral? How shall we treat the German property, in which only the market value exists, but not the mortgage lending value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1023
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Geographical Breakdown

We have found differences between the package provided by our XBRL suppliers and those supplied by EBA mainly with regards to geographical breakdown.The problem is regarding total sheets whether these should be included or not and the list of countries that should be reported in the respective sheets. Our XBRL suppliers suggested we contact EBA for further clarification as the instructions and the reference ( please see link below) made in the instructions to Article 96 of the CRR are not clear. The EBA Q&A questions already submitted which refer to geographical breakdown deal mainly with threshold issue, while we need clarifications regarding the list of countries and total sheets. http://www.eba.europa.eu/documents/10180/603236/Draft---ITS-on-reporting... For example for table C 15.00 : Extract from Annex IV found in the above link states: “3. Geographical breakdown 9.11. According to Article 96 paragraph 1 second sentence of CRR this template is reported for separately for each property market within the EEA to which the relevant institution is exposed to.”

  • 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: 2014_1019
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Start of Probation Period

For exiting the non-performing category Art. 17 no. 157 requires that one year has passed since the forbearance measures were extended. Does that mean that, a) the probation period starts already at the date of the forbearance measure. b) The probation period starts only when the exposure is no longer considered impaired or defaulted.

  • 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: 2014_1018
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Exit Criteria NPE

The exit criteria described in No. 157 “shall apply in addition to the criteria applied by reporting institutions for impaired and defaulted exposures”. Does that pose any further requirement other than ‘the exposure is not in default’ and ‘the exposure is not impaired’?

  • 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: 2014_1017
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Tracking of Past-due amounts

In our view, the criterion “there is not, following the forbearance measures any past-due amount” must be met at the date when the exit criteria is examined (regardless whether there have been any past-due amounts before that date but after the extension of the forbearance measure). Do you agree?

  • 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: 2014_1016
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015