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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.

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List of Q&A's

Validation rules v10817_m for MREL/TLAC

Is it correct that validation rule v10817_m considers r0550, c0010 of template M 03.00?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2021_6275
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 22/02/2023

Scope of prudential consolidation

Does the answer to Q&A 2019_4711 also apply to those cases where a consolidated requirement is triggered by Regulation (EU) 2019/2033 (IFR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6274
  • Topic: Other issues
  • Date of submission:

Jump-to-default risk weights in specific reporting requirements for market risk

Which risk weights should be used in the case of multiple exposures in different seniority classes and credit quality steps to the same obligor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/453 - ITS with regard to the specific reporting requirements for market risk
  • ID: 2021_6273
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Aggregation of risk-class specific own funds requirements for delta, vega and curvature risks

Should own funds requirement for Sensitivities Based Approach  be the sum of GIRR, CSR, Equity and Forex requirement arising from the scenario with the highest total requirement value? or result from the scenario with the highest total requirement at the individual asset level class? And how to calculate the requirement in Article 325h(4)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6272
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Negative sensitivities on C91.00 columns 0020 and 0030 - validation rule v10242_s

Should the net delta sensitivities in columns 0020 and 0030 of template C91.00 be reported as absolute values?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6271
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2022

Trading book business for the purposes of Article 94 CRR

What is meant by "positions concerning foreign currency"? Any derivative contract that has a currency pairs as underlyng (e.g. forex swap, forward foreign exchange contracts, cross-currency interest rate swaps, option currency)? Also contracts settled in currencies other than the reporting currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6270
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

The size of all non-trading book positions that are subject to foreign exchange risk

According to article 325a, paragrhap 2, is the size of all non-trading book positions that are subject to foreign exchange risk equal to the higher between the total of the net short positions and the total of the net long positions computed according article 352 or is it the sum of absolute value of total of the net short positions and the total of the net long positions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6269
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Threshold calculation for Corep C90.00 sheet

We would like to ask for assistance to determine how to handle our so called „FI Margin” product from 30/09/2021 in the case of threshold calculation for Corep C 90.00 sheet – based on the trading book activity and market risk. The main scope of this particular product is that the investors are allowed to make a bet based on their expectations on the Governement bond market by using only a small amount of margin. (So this product has a high-level leverage.) The risk of the client-based deals are hedged with prompt deals on Government bonds. The two deals (i.e. the client-based and the hedge one) belong to one product which one can rank as a derivative product. As of our understanding, one can net the spot (hedge) and forward (client) leg of the „FI Margin” product, thus no bond interest rate risk position arise and we can report only the open derivative position, which arise from the market value of the two legs together.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6268
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2022

Classification of loans collateralized by residential and commercial immovable property

According to Annex V (FINREP), ‘Loans collateralized by immovable property’ shall include loans and advances formally secured by residential or commercial immovable property collateral, regardless of their loan/collateral ratio (commonly referred as ‘loan-to-value’) and the legal form of the collateral. In the case of an exposure collateralized by both a residential and a commercial immovable property, where just one of the two collaterals (e.g. Residential) is capable of securing all of the exposure and is the only collateral allocated so that the commercial immovable property is formally and contractually associated to the exposure but it is not allocated, how shall such loans be represented? • Loan collateralized by residential and commercial immovable property, being the existing formal/contractual relationship; • Loan collateralized by residential immovable property, assessing the real allocation of the collateral in consideration of collateral capacity and ability to back the loan.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6267
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/03/2023

COREP C91.00 - Consistency control v10242_s

The validation report of the COREP is failing due to the taxonomy rule v10242_s which is expecting positive amounts in the column C0030 on template C91.00. The instructions state that: “Institutions shall report the sum of net all positive and all negative sensitivities to the different delta risk factors within a risk class”. Should this control be reviewed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6266
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2022

Validation Rule EGDQ_0480

Is it correct that the Validation Rule doesn’t take into account the total amount of past due >90 days exposures in F07.01 excluding those in C 0120?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6265
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2022

Validation rule v6011_h

The validation rule v6011_h checks if the accumulated impairment of loans and advances for non-financial corporations (row 190) is lower than the sum of accumulated impairments of small and medium-sized enterprises (row 200), belonging to non-financial corporations. In most cases the accumulated impairment is negative. e.g.: Impairment = - 40 r190 (Loans and advances NFC) = -40 r200 (of which: SME) = 0 In this case c190 < c200 and the validation rule is not violated. The question is, how should we deal with positive accumulated impairment due to POCI deals? e.g.: Impairment = + 40 r190 (Loans and advances NFC) = +40 r200 (of which: SME) = 0 In this case c190 > c200 and the validation rule is violated, although positive impairment is generally allowed.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6264
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2022

Common Equity Tier I Minority Interest Calculation

Should a specific level of profit distribution set by a third country competent authority, and communicated specifically to an institution, be considered “any additional local supervisory regulations in third countries insofar as those requirements are to be met by Common Equity Tier 1 capital” for the purposes of the minority interest calculation provided in Article 84 1 i) and ii))  when this limit has been set above legislative prudential requirements with the aim of preserving capital above an specific limit by the way of limiting profit distribution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6262
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Reporting non performing exposures into days past due time bands

Table F 18.00 of FINREP contains the breakdown by past-due time bands of performing and non-performing exposures. How shall time bands of non-performing exposures be reported? Using days past due or material days past due?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6263
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2022

Application of Articles 52 and 54 of Regulation No. 575/2013 (CRR) at consolidated level

How should the consolidated level of AT1 instruments where the issuer is a 100% fully owned subsidiary of an EU institution where the subsidiary is established in a third country and has not been designated in accordance with Article 12 of Directive 2014/59/EU (BRRD) as part of a resolution group the resolution entity of which is established in the Union be treated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6261
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Purchase of credit receivables as a form of 'granting credits'

  Should the purchase of credit receivables be classified as 'granting credits' within the meaning of CRR's definition of credit institution? And if so, would a subject (a natural or legal person) whose activity is that of repeatedly purchasing credit receivables from a credit institution and concurrently taking deposits or other repayable funds from public, be required to obtain a license under Article 8 CRD?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6257
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/03/2023

Payee-initiated transactions with irregular period or variable amounts for account payments.

Please clarify whether payee-initiated account transactions available in Account Servicing Payment Service Providers (ASPSPs)’ online banking channels are considered discriminatory under PSD2 when not available in the PSD2 Application Programming  Interfaces (APIs). 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6256
  • Topic: Other topics
  • Date of submission:

Obligation to report risk-weighted exposures under SEC-ERBA and under SEC-SA as memorandum items in COREP template C 14.01

When does the obligation apply to report risk-weighted exposures under SEC-ERBA in column 0447 and under SEC-SA in column 0448 of template C 14.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6252
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Application of strong customer authentication (SCA) where Account Information Service users access the Account Information Service Providers’ (AISPs) own channels and the previously retrieved payment account information compiled and stored therein

Are Account Information Service Providers (AISPs) exempt, in respect of their own channels, from the requirements of Article 97(1) of Directive (EU) 2015/2366 and of Article 10 of Regulation (EU) 2018/389, and therefore allowed: to let users of their Account Information Service, access the AISPs’ own channels and the payment account information compiled and stored therein – previously retrieved by AISPs from the users’ respective Account-Servicing Payment Service Providers (ASPSPs) – without applying any strong customer authentication (SCA) upon that access to AISPs’ own channels, irrespective of whether the conditions of Article 10 of Regulation (EU) 2018/389 are satisfied – such that AISPs may, in their own channels, allow users of their service to consult, without SCA, previously retrieved payment account information of a broader scope (more than the last 90 days’ worth of data, and potentially the users’ complete transactional history) as compared to the data that ASPSPs may, without SCA, display to the same users in the ASPSPs’ own channels (maximum the last 90 days’ worth of data, and provided that SCA was applied no more than 90 days prior) – and such that AISPs, despite being payment services providers (PSPs), need not afford users of their services the same level of protection that ASPSPs are required to, and can expose said users to the risks of abuses referred to in Article 97(1)(c) of Directive 2015/2366?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6248
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

Change of TPP access rights for AIS consent by the PSU prior to authorisation

A clarification / harmonised guidance on the Scope of the Bank Offered Consent, as defined in the Berlin Group standard, is needed.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6246
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/10/2022