Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Counterparty Zuordnung Abwicklungsanstalten

Für FinRep sind in verschiedenen Tabellen Aufgliederungen nach sog. Counterparties erforderlich. In der Praxis stellt sich häufig die Frage, in welchen Sektor Abwicklungsanstalten einzuordnen sind. Hierunter fallen in der Praxis regelmäßig gehaltene Positionen ggü. der Heta Asset Resolution AG, der Erste Abwicklungsanstalt (EAA) sowie der FMW-Wertmanagement. Auf Basis der Counterparty-Definition in Annex V (1.35) ist in der Praxis ein eindeutige Zuordnung nur schwer möglich. Insofern stellt sich die Frage nach einer aus Sicht der Aufsicht korrekten Zuordnung von gehaltenen Positionen gegenüber den o.g. Gesellschaften.For Financial Reporting, breakdowns by ‘counterparties’ are required in various tables. In practice, this frequently gives rise to the question of which sector should be used for deconsolidated environments. This includes, in practice, positions regularly held in respect of Heta Asset Resolution AG, Erste Abwicklungsanstalt (EAA) and FMS Wertmanagement. On the basis of the counterparty definition in Annex V (1.35), a clear classification is difficult in practice. In this respect, there is a need to correctly (from a supervisory perspective) classify positions held in respect of the above-mentioned companies.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2016_2789
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Short positions in financial institution capital instruments

1. For a contract between bank A and B as set out in the background that is a forward sell (physical delivery), can Bank A deduct from its own funds the net position on FSE?2. For a contract between bank A and B as set out in the background that is cash-settled (TRS, future, options), can Bank A deduct from its own funds the net position on FSE?

  • 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: 2016_2785
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 30/06/2017

Outflows from operational deposits

What is the difference between deposits arising from clearing accounts of financial institutions and deposits arising from correspondent banking?

  • 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: 2016_2784
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 26/08/2016

‘Indirect holdings’ in capital instruments issued by financial sector entities (CRR Article 4 paragraph 1 subparagraph 114).

The definition of indirect holdings requires that the institution performs an internal assessment in order to determine if, in the event the capital instruments issued by the financial sector entity were permanently written off, the loss that the institution would incur as a result would not be materially different from the loss the institution would incur from a direct holding of those capital instruments. Can the institution use stress scenarios that are already utilised by the institution for internal risk management purposes when making this assessment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2783
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 28/10/2016

EBA Benchmarking 2016

In template C 103.00 ”Details on exposures in High Default Portfolio”, column 230 and 240, it is demanded the RWA* and RWA**. For those purposes, we need to calculate a PD* and PD**. Our question is about how PD* must be estimated. In this sense we have read the specifications and we need more clarifications or be sure our understanding is correct.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2782
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 02/12/2016

Termination date

1cFor portfolio 1.28, should the scheduled termination dates be 5 years (i.e. December 2020) rather than 4 years 1d and the answer was 1cThe scheduled termination date is 20/12/2020 1d. However, Section 2.7 of Annex V refers to scheduled termination date of 20December 2019. Should the termination date be December 2020?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2776
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Is collateral from REPO and SBL transactions taken into consideration for the BRRD base calculation?

Could liabilities arising from repos and securities lending and borrowing transactions be netted with the collateral posted what would result in a BRRD base decrease?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2016_2765
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 12/08/2016

Capability to perform an impact analysis for 15 consecutive business days for extensions and changes of internal approaches for market risk

Do the regulatory technical standards for assessing the materiality of extensions and changes of internal approaches when calculating own funds requirements (Delegated Regulation (EU) No 529/2014, as amended by Delegated Regulation (EU) 2015/942 for market risk) imply that institutions using internal approaches for market risk shall have the capability to perform a parallel run for 15 consecutive business days for all model changes in their market risk models, such that the materiality of the extension or change can be assessed in accordance with Article 7a(1)(c) of that regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2015/942 - RTS on materiality of extensions and changes in internal approaches for market risk
  • ID: 2016_2763
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/01/2017

Template C 69.00 - Prices for the Various Lenghts of Funding - follow-up to Q&As 2015_1901 and 2015_2204

We note response given to question 2015_1901. Can we clarify if the treatment advised for retail current accounts also applies to cash operating accounts used by corporate entities?We note response given to question 2015_2204, could we request a definition of ‘new transactions entered into during the period’ in the case of cash accounts for the purpose of calculating the total volume reported. Is that treatment consistent to both retail and corporate cash accounts?

  • 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: 2016_2761
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

NSFR - Definition of Other Equity Instruments

How are Other Equity Instruments defined? Are Investment Funds (OGAW and AIF) considered as Other Equity and therefore reported in lines 720 to 770 of the NSFR? If not, in which line are Investment funds to be reported if they dont qualify as liquid assets.

  • 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: 2016_2760
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reported overshootings in C 24.00

How should the number of overshootings in VaR be reported in C 24.00?

  • 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: 2016_2759
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

VaR Multipliers

How should the figures in VaR and SVaR multiplication factors be reported in C 24.00?

  • 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: 2016_2758
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Calculation of the threshold for using the simplified approach for the determination of AVAs.

Exactly matching, offsetting fair-valued assets and liabilities shall be excluded from the calculation of the threshold for the simplified approach in the determination of AVAs. Does “exactly matching” refer to specific conditions regarding the counterparties of assets and liabilities that otherwise may qualify to be offset?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2016_2756
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Definition of mortgage loan and its collateral in FINREP template 13 (F13.01)

1. What kind of loans should be reported as “Mortgage Loans” for the purposes of FINREP template F13.01? 2. What kind of commercial and residential property should be reported as collateral for “Mortgage Loans” for the purposes of template F13.01?

  • 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: 2016_2754
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Clarification on the treatment of regular clearing positions of central counterparties (CCPs) in the leverage ratio exposure measure (provided CCPs are subject to leverage ratio regulation)

Can you confirm that positions which arise from a CCP’s primary clearing activity and which are already covered by EMIR-compliant risk management tools are to be excluded from the LR exposure measure?

  • 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: 2016_2750
  • Topic: Leverage ratio
  • Date of submission:

Reporting of individuals/households names in template C 67.00

Should the individuals/households names to be disclosed when filling template C 67.00?

  • 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: 2016_2743
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

The treatment of Physical Stock balances

The ITS states firms should report the name of the top ten issuers/counterparties of unencumbered assets or undrawn committed liquidity lines granted to the institution shall be recorded in column 010 in a descending fashion.-       If a firm holds gold or other commodity stocks, does column 010 (counterparty name) need to be populated?-       Should all physical stock balances be reported on one line? 

  • 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: 2016_2742
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Can the same issuer / counterparty appear more than once in the top 10 of template C 71.00 based on currency?

The ITS states firms should report the name of the top ten issuers/counterparties of unencumbered assets or undrawn committed liquidity lines granted to the institution shall be recorded in column 010 in a descending fashion. The ITS also requires a currency to be assigned to the Issuers/counterparties. If you hold assets from a counterparty that are issued in different currencies do you report the counterparty more than once? Or do you report the currency of the largest proportion of the total.

  • 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: 2016_2741
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

LCR treatment of cash pooling services

Due to limitations on the withdrawal of deposits, should individual deposits covered by a single cash pooling agreement be treated as individual deposits to which the outflow rates specified in Article 28 of the Delegated Regulation 2015/61 apply, or rather as a new type of product that would be covered by Article 23 of the Delegated Regulation? Alternatively, could inflows and outflows from cash pooling services be treated as interdependent inflows and outflows as per Article 26 of the Delegated Regulation? Or could the individual positive and negative balances covered by a single cash pooling agreement be considered on a net basis in order to determine the applicable outflows or inflows?

  • 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: 2016_2740
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 22/09/2017

Treatment of exposures to non-EU equivalent investment firms, non-EU equivalent credit institutions and non-EU equivalent exchanges.

1. With reference to EBA Q&A 677, what is the regulatory basis/rationale in your decision to treat a non-EU equivalent third country exposure to recognised exchange as an exposure to a corporate? Please reference the CRR/ Single RuleBook in your response.2. Does the treatment describer in Q&A 677 or non-EU equivalent recognised exchanges also apply to exposures to non-EU equivalent investment firms and non-EU equivalent credit institutions so that they will also be treated as exposures to corporates? Please reference the CRR/ Single RuleBook in your response.3. Should these exposures be reported (C07 CRSA) in the exposure classes Institutions or Corporates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2739
  • Topic: Credit risk
  • Date of submission: