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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

Clarification for filling the 'Not applicable' value in Annex II and IV

To clarify the meaning of the value 'Not applicable' within Annex II. In some cases the 'Not applicable' value seems to represent a total portfolio (refer to Example 1). In other case, the 'Not applicable' value seems to mean that the driver is not significant for the specific cluster of analysis (refer to Example 2). In other cases, the 'Not Applicable' value seems to be a residual value (refer to Example 3). Summarizing, does the meaning of 'Not applicable' depend, in Annex II, on the considered field or it always represent a total portfolio? For every field of Annex IV, 'Not applicable' shall be used always when none of the answers in the list is correct, therefore does it represent a residual cluster?

  • 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: 2015_2291
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

A confirmation is required about the rules to fill the EBA Benchmarking templates

Could you confirm whether the following interpretation is correct? Fields of Annex I and the relevant values define the benchmarking portfolios (i.e. the portfolio of analysis identified by the portfolio ID). The same exposure can be included in more than one portfolio_id only in case it is clearly specified in the EBA instructions (i.e. refer to Example 1). For all the other fields the values listed in Annex I have to be considered mutually exclusive (i.e. the same exposure cannot be associated to two different values, with the exception of the 'Not applicable' value). For each portfolio id, Institutions have to fill the information contained in Annex III. These information have to be aggregated in case they are defined at a lower level than the relevant portfolio id (refer to Example 2). According to Annex I (template 103) Rating is not a segmentation criteria (not applicable), but in Annex II (template 103) the internal Rating grade shall be inserted. This would mean that: - is not the portfolio_id unique and an artificial further segmentation would be created? - should the rating grade be dependent on the average PD which was calculated for that portfolio? - is the field 'Rating' indeed required also in Annex I (template 103), i.e. the 'Not applicable' value, indicated in Annex I (template 103) is not significant

  • 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: 2015_2290
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Identification of exposures treated under Standard approach

The part of transactions which is secured by guarantees could be moved to the permanent partial use, i.e. standard approach. RTS, page 34, point 10, states that: 1e [ 26] As a result, the benchmarking exercise should only relate to validated internal approaches. Institutions should not provide data for those portfolios which include instruments or risk factors that are reported under the standardized rules. 1d What exactly is meant with 1cportfolio 1d? Shall only be a part of the transaction be excluded (part which is STC), shall the customer be excluded or the portfolio of which the transaction/partner is part of?

  • 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: 2015_2288
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Reporting of individual exposures relating to a group of connected institutions for which there is a cash pooling agreement, where some creditor nostri accounts are offsetting debtor nostri balances

Our institution has a cash pooling agreement relating to three bank accounts opened in different banks belonging to the same Group, so that cash transfers are processed automatically overnight to one centralizing bank account.Up to now, in the LE2 template, we have been reporting the resulting net exposure on this group of connected counterparties and in the LE3 template, the detail for each of the three counterparties, but we have been encountering the following validation rule blocking errors: v0648_m, v0649_m,  v3799_s and v3802_s. These errors are due to the input of a negative outstanding for one of the banking counterparts, corresponding to a creditor nostro balance.Our question is how to fill in the LE3 template in this situation ?

  • 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_2286
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/08/2017

C 22.00 (Market Risk FX) - Scope of Memorandum Items

Please clarify whether the Memorandum Items on COREP template C 22.00 (Market Risk FX) which are to be reported on rows 130 and below should include all of an institution's gross and net FX positions, regardless of the approach used for capital requirements of these positions. Please also clarify whether these items should be reported by all institutions with the relevant COREP reporting requirement, or only by those institutions which meet (i.e. exceed) the 'de minimis' threshold defined in Article 351 CRR.

  • 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_2285
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

FinRep Table 2: Interest income & Expense: Derivatives – Hedge accounting, interest rate risk

How should interest income & interest expense on derivatives (hedge accounting) be presented in Table 2 ? (i) Linked basis: Reported in Interest Income (row 070) if the derivative is hedging an asset item and Reported in Interest Expense (row 130) if the derivative is hedging a liablity item OR (ii) Gross basis: Hedge accounting derivatives resulting in Interest Income should be reported in row 070 and hedge accounting derivatives resulting in Interest Expense should be reported in row 130.

  • 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_2284
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Application of the even deduction rule in case of intragroup transactions booked - by institutions which are parties to the contract - in different amounts

How to apply the even deduction rule stipulated in the Article 5(2) of the Commission Delegated Regulation (EU) 2015/63 and further clarified by the EBA Q&A 2015_1893 (Treatment of specific liabilities - even deduction) in cases where each party books the transaction in different amount?

  • 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: 2015_2283
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 05/08/2016

Completion of Annex I, Template C103.00 of the ITS needed?

For the high default portfolio benchmarking exercise we have noted that Annex I, Template C103 of the ITS is not included in the "DPM Table Layout and Data Point Categorisation 2.3.1.zip" for benchmarking on the EBA’s website: https://www.eba.europa.eu/-/eba-publishes-updated-dpm-and-xbrl-taxonomy-... Article 2(1)(c) of the “EBA Final Draft Regulatory Technical Standards on benchmarking portfolio assessment standards and assessment sharing procedures under Article 78 of Directive 2013/36/EU” refers to this template, but does not state that the template needs to be completed. Is completion of the Template C103 from Annex I required for the April 2016 benchmarking submission?

  • 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: 2015_2282
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification regarding the reference year for the purpose of the remuneration data to be collected by Competent authorities

The guidelines specify that data reported should relate to remuneration awarded to staff for the performance year preceding the year in which the information is submitted. To which amounts and year does the guideline refer exactly with regard to the collection of the fixed and variable component of remuneration?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/07 - Guidelines on data collection exercise regarding high earners
  • ID: 2015_2276
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/01/2016

Clarification regarding the reference year for the purpose of the remuneration data to be collected by competent authorities

The guidelines specify that data reported should comprise fixed and variable remuneration awarded for performance during the performance year preceding the year of submission of the information? To which amounts and year does the guideline refer exactly with regard to the collection of the fixed and variable component of remuneration?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/08 - Guidelines on remuneration benchmarking exercise
  • ID: 2015_2275
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/01/2016

Market, Credit and Counterparty risks of Central Counterparty under CRR

For Central Counterparty (CCP) acting under Regulation (EU) n°648/2012 (EMIR) with a banking license, - Should the risks already covered by specific financial resources as referred to in Articles 41 to 44 of EMIR be subject to capital requirements under Regulation (EU) n°575/2013? - Should the risks towards a CCP arising from an interoperability arrangement which fulfilled the requirements referred to in Articles 52 and 53 of EMIR and already covered with such requirements be subject to capital requirements under Regulation (EU) n°575/2013?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2274
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

F35.00 Covered Bonds - Solo Legal Entity Split

How should we report Solo Legal Entities cases, where assets are included in the covered bond pool, but the liabilities are held on another entity's balance sheet?

  • 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: 2015_2272
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F35.00 Covered Bonds - Maturity profile of covered assets

How should the maturity profile of the covered assets be reported?

  • 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: 2015_2271
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F35.00 Covered Bonds - FX rates to be applied

There are circumstances where the covered bond has been issued in one currency and the underlying assets are in a different currency. In which case, the covered bond programme would hedge this cross currency risk. In this circumstance, which FX rate should be applied? The spot FX rate as per the reporting date or the strike FX rate as per the swap agreement?

  • 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_2270
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

F35.00 Covered Bonds reporting of over collaterization

In Rows 020 and 030, Columns 220-250, are UK banks required to complete these cells if over collateralisation is determined on a nominal basis as per UK covered bond regulations?  If so, how should over collateralization be translated into Present Value (what discount rate should be applied) or how should we determine the Asset Specific 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_2269
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Appropriate risk weight for speculative immovable property financing

Does CRR Article 128 (1) provide that a 150% risk weight need not be applied to one or more exposures listed in CRR Article 128 (2) - including speculative immovable property financing - or that are identified in accordance with CRR Article 128 (3), on the basis that it would not be appropriate to apply that rate to such an exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2268
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/10/2016

Treatment of derivative liabilities in the denominator of MREL

What does Article 45 (1) of Directive 2014/59/EU (BRRD) mean by including derivative liabilities in the total liabilities on the basis that full recognition is given to counterparty netting rights?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2266
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Differentiation between specialised lending and sme exposures within exposure class corporates

The exposure class 'corporates' is splitted into sme, specialised lending and other corporates. Where must an institution report specialised lending exposures, that are at the same time exposures to sme? The implemented sme definition only the annualised returns (< 50 mln. EUR). Specialised lending exposures are identified through the rating methodologies, that have been applied to determine a credit quality.

  • 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_2259
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Calculation of Default rate past 5 years and Loss rate past 5 years

If bank applies AIRB models to RWA calculation (according with the decision of the competent authority) for a period shorter than 5 years, what time series should be used for calculation of 5-year average values when calculating default rates and loss rates ?

  • 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: 2015_2257
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission: