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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

Exposure class - Corporate - Specialised Lending

Does Annex I have a value of "Corporate - Specialised Lending" for exposure class?

  • 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_2418
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C103.999 - Exposure

Is it necessary to populate the "Exposure" field 103.999 in template C103?

  • 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_2416
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Should National GAAP reporters fill in template F 18.00 and F 19.00 on non-preforming and forborne exposures?

Should National GAAP reporters fill in template F 18.00 and F 19.00 on non-preforming and forborne exposures?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2415
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Exclusions of liabilities matched by promotional loans

According to Article 5 (1) (f) of Commission Delegated Regulation (EU) 2015/63, can exclusions of liabilities matched by promotional loans be greater than the sum of promotional loans themselves?

  • 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_2414
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 30/10/2015

Recovery rate of the foreclosure assets calculation

Regarding to the Supervisory Benchmarking Process, Annex III, C 105.01:When calculating the recovery rate of the foreclosure assets, should the recovery rate include a prediction for LGD for the recent defaults or only observed recoveries are expected? 

  • 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_2412
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Definition of portfolio 1.2

Google does not exist anymore. Alphabet Inc. was created as a subsidiary directly owned by Google Inc. The restructuring process was completed on October 2, 2015. Alphabet retains Google Inc.'s stock price history and continues to trade under Google Inc.'s former ticker symbols "GOOG" and "GOOGL". In the description of the portfolio 1.2, it is written: “Long 100 contract OTC Google (GOOG) OTM 3-months call options.” Could you please clarify if we should book on: - Alphabet Inc Class C (GOOG) - Alphabet Inc Class A (GOOGL)

  • 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_2410
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Type of Facility, Annex II - Table C103 - Column 070 (k)

Are facilities like "unissued guarantees, stand by letter of credit and warranties" as mentioned in Annex II, table C103, column 070 k) in scope of this reporting?

  • 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_2409
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Type of Facility, Annex II - Table C103 - Column 070 (g)

Could you please provide an example of what type of facilities shall be classified as "Undrawn purchase commitments for revolving purchased that are able to be unconditionally cancelled or that effectively provide for automatic cancellation at any time by the institution without prior notice" as per point g) of column 070 in table C103?

  • 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_2408
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Scope of reporting on 11.04.2016

In respect of reporting date 11.4.2016 we are supposed to report only about the details on exposures in 1cHigh Default Portfolios 1d in table C.103. Is it correct to assume that for our submissions in respect of tables C.105.1 1cDefinition of internal models 1d and C.105.2 1cMapping of internal models to portfolios 1d we would also only be required to submit information only in respect of 1cHigh default portfolios 1d, i.e. for the same portfolios as reported about in template C.103?

  • 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_2407
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Levels of reporting

Please clarify whether this reporting exercise requires also the submission of data at sub-consolidated level, apart from consolidated and solo level.

  • 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_2406
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Securitisations and equity exposures

Are the securitisations and equity exposures in scope of this reporting exercise? If yes, the securitisations and equity exposures shall be classified in the Exposure Class: "(i) Not applicable" in table C103, column 020?

  • 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_2405
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Joint Decision - Annex III - C105.01 - Column 110

Column 110 of table C.105.01 as per Annex IV shall be filled in just with "Yes" or "No"?

  • 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_2404
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Assignment of Mortgage Exposures to Portfolio IDs

Please clarify to what Portfolio ID(s) shall be assigned a non-defaulted mortgage exposure with a real estate collateral and a LTV of 70%. Shall it be included in "Mortgages Non-defaulted funded Credit Risk Mitigation (e.g. collaterals)" or in "Mortgages Non-defaulted ILTV >50%,<=75%" ? Or in both portfolios?

  • 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_2402
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Portfolio ID Unique Row Identifier in template C 103.00

Is column 010, Portfolio ID, of table C.103, supposed to be unique for each row in the table C.103, as per Annex IV? Or rather, it is the unique Portfolio ID as provided in column 010 of table 103 of Annex I, without being a unique row identifier in table C.103 as per Annex IV?

  • 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_2401
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification on lower barrier level for portfolio number 1.16 (FX) from Annex V

Considering current market (EUR/USD = 1.1374 ), should an adjustment to the lower barrier level defined in Section 2.5 to be expected?

  • 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_2400
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarifications on Portfolio 1.4 from Annex V (Long/short puts on FTSE 100)

Does Portfolio 1.4, described in Annex V, require exchange traded options? If there is no exact 10% ITM and OTM instrument available on the exchange - should the instrument available with a strike price nearest to the 10% OTM/ITM be taken? Or should an OTC option FTSE with exact strike prices be captured?

  • 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_2399
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Benchmarking exercise - market risk - clarifications on Annex V portfolios

Annex V - portfolio 1.16 (Double no touch option): Not only is the option worthless, it also knocks out immediately given the current level of spot (1.13). For the 2014 exercise, the level of spot meant that the option was in-the-money at the time of trade entry, however, it appears that the barrier levels have not been updated. As a result, unless the barrier levels are updated, systems may not allow the trade to be booked (it ceases to exist). How should firms handle this? Annex V - portfolios 1.17 and 1.18. What is the underlying currency (which is different from the reference currency) of portfolios 1.17 and 1.18 for Commodity? Are the risk factors for these trades specified in USD or EUR? For example, are the oil put options priced using USD WTI (spot and volatility)? If priced using EUR risk factors, the trades will create cross currency basis risk which will need to be included in the VaR results.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2398
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Own estimates of CCF in the retail exposure class

For which product types has a credit conversion factor (CCF) to be used in the retail exposure class, which is based on own estimates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2397
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 05/05/2017

Applying a currency mismatch haircut to OTC derivatives in a netting pool which are in a currency different from settlement currency

For OTC derivative transactions covered by master netting agreements, if the exposure (derivative) currency is different from the settlement currency, should the exposure amount be increased by the currency mismatch haircut?While calculating the replacement cost of the derivatives, should the exposure amount be increased by the currency mismatch haircut?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2394
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2016

Investment in Tier 2 capital by subsidiary

Article 63(b)(ii) of Regulation (EU) No 575/2013 (CRR) states that capital instruments and subordinated loans shall qualify as Tier 2 instruments provided that particular conditions are met. One of such condition requires that the instruments are not purchased or the subordinated loans are not granted, as applicable, by either the institution or its subsidiaries.Is it a correct approach that only the part of capital instruments which is not currently held by subsidiary should be qualified as Tier 2 instruments?Should an institution apply for permission for the whole issue and after that exclude instruments held by subsidiaries, if national law requires a special permission from the competent authority in order to recognize instrument as Tier 2 capital? And after being granted this permission should the institution exclude in day-to-day adequacy calculation the amount of instruments held by subsidiary?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2392
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/07/2016