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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

Reference to Chapter III in Article 96(3)(b)

Is the reference to Chapter III in Article 96(3)(b) correct?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3703
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Enforce a third country resolution proceeding

How should the outcome under Article 94(4)(d) be achieved and in what way is that article different from the provision under Article 68?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3702
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Clarification on the authority responsible for the DGS

Which exactly is the authority responsible for the DGS referred to in Article 88?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3701
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Other groups or colleges in Articles 88(6) and 89(4)

Could you please explain what “other groups or colleges” can carry out the work assigned to the resolution colleges with regard to Articles 88(6) and 89(4)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3700
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Intervention of the resolution fund to cover for losses due to creditors / liabilities excluded from bail-in

Can Article 101(2) of Directive 2014/59/EU (BRRD) be interpreted in the way that even if all bail-inable creditors have been subjected to bail-in and losses are still not covered, a bridge bank would not be allowed to take on the remaining losses and thus resolution would not be possible?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3699
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Clarification regarding the consideration in Article 42(6)

Can you please clarify Article 42(6) of Directive 2014/59/EU (BRRD); regarding that the consideration can have a nominal or negative value? Does effect of this mean that the asset management vehicle (AMV) must owe a debt to the institution under resolution?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3698
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Valuation in Article 36

How should the resolution authority perform the valuation mentioned in Article 36 of Directive 2014/59/EU (BRRD) before making the decision initiating resolution if it is not entitled to require certain information from the particular entity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3697
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Conditions for Early intervention

What are the conditions for Early intervention in Article 27(1) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3696
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 09/03/2018

Definition of 'explicit guarantee arrangements' for the purpose of classification of non-commercial undertakings as public sector entities

What conditions should be met by a given agreement in order to qualify as an 'explicit guarantee arrangement'?Shall the ‘explicit guarantee arrangements’ for the purpose of definition of public sector entities also be ‘guarantees’ eligible as unfunded credit protection or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3694
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule v_1044_m (FINREP template 16.3 IFRS9)

The validation rule v1044_m requires that for template F 16.03 the following condition is fulfilled: {r090} = sum(r010-080).However, in taxonomy v2.7 template F 16.03 has been amended: row 015 (of which: Economic hedges with use of the fair value option) has been added. Is the validation rule v1044_m still valid?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3692
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Reporting reference dates for template C 33.00

Could you please confirm what the first reporting reference date for the sovereign exposures template (C 33.00) for institutionsi. who report on a calendar year basis (i.e. accounting reference date 31 Dec)ii. whose accounting reference date deviates from the calendar year (say 31 March) and are permitted to apply Article 2(3) of Regulation (EU) No 680/2014is?

  • 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: 2018_3691
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template

How should (banking) holidays and weekends be reflected in C 70.00 (zeros, empty lines or constant volumes)? How should an internationally active credit institution with subsidiaries in different countries reflect holidays in different countries and working days in the weekend? Is there a different approach to be taken for non-maturity funding versus term funding in light of weekends and (banking) holidays?

  • 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: 2018_3689
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Annexes I & II, C 18.00, validation rules v4850_m and v4851_m.

Is there an error in the validation rules v4850_m and v4851_m applicable to template C 18.00? 

  • 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: 2018_3682
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Committed liquidity facilities to a special purpose vehicle (SPV)

Figure 4.1.2 of ANNEX XIII clearly refers to Article 31 or Regulation (EU) 2015/61, which is the regulatory basis of the LCR. According to Article 31 committed liquidity facilities to SPVs which have a maturity date above 30 days are not considered within the Outflows. Therefore we would not consider these cash flows in row 1130. Row 1090 has no reference to Art. 31 of the LCR and it states the requirement '[...] the maximum amount that can be drawn in a given time period'. Is it correct to show above mentioned cash flows only in row 1090?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3681
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Validation rule v5053_m in DPM 2.7.0.1

For all rows in template F12.01a the validation v5053_m states: {c100} = sum(c010-090). Is it correct that including row 350 (of which: non-performing) is an error in validation v5053_m?

  • 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: 2018_3680
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Impact of a profit and loss transfer agreement under German company law on the eligibility of CET1 instruments for subsidiaries having full discretion on contributing common equity tier 1 capital as defined in Article 26 of the CRR

According to Q&A 408, an agreement an institution has entered into with its 100% parent entity, pursuant to which the institution must transfer its profit for the period to the parent entity (and the parent entity must cover any losses) constitutes an obligation to distribute (mandatory distribution), which is not permitted under Article 28(1)(h)(v) of the CRR. Is the case different where the institution is free to decide to set aside reserves from profits generated, according to its own commercial judgement or discretion, hence avoiding a profit transfer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3675
  • Topic: Own funds
  • Date of submission:

Taxonomy 2.7.0.1 Validation Rules on FINREP 12.01

According to rule v5054_m, the total of the stage one allowance is limited to the provision for expected losses on household exposures only. Should this rule be superseded by v5554_h? Using the former rule will understate the true amount of the allowance.

  • 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: 2018_3673
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Template CRGB sheet 01 and 02

In Regulation (EU) 2017/2114 amending Regulation (EU) No 680/2014, in Annex II paragraph 3.4, no sheet ‘Total’ is described for CRGB1 and CRGB 2. Only in paragraph 3.4.4.1 a sheet Total is described for CRGB 04.But a release note on taxonomy 2.7 seems to say that a total sheet is now mandatory for CRGB1 and 2. Is it true?There are 63 validation rules between templates C 09.01 and C 07.00 which have an expression similar to this ‘sum({C 09.01.a, r010, c010, (sNNN)}) = {C 07.00.a,  r010,  c010,  s002}’.Additionally, there are 76 new validation rules of type eQuivalence which have an expression similar to this ‘{C 09.01.a,  r010,  c010,  [CEG=eba_GA:x1]} = {C 07.00.a,  r010,  c010,  s002}’.There are also 39 validation rules between templates C 09.02 and C 08.01 which have an expression similar to this ‘sum({C 09.02, r130, c010, (sNNN)}) = {C 08.01.a, r010, c020, s017}’.Which of these rules and how shall these rules be applied successfully?

  • 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: 2018_3672
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Discrepancies between annotated table layout and EBA validation rules (e.g. v5351_m)

1) Are the columns 011, 012, 022 and 025 of template F 20.04 in the annotated table layout (FN1) not intended to be subsets of column 010, meaning that a limitation on ‘other than held for sale’ in column 010 would indicate the same limitation for the ’of-which’ columns?2) If there is a limitation on ’other than held for sale’ in template F 20.04, column 010, does this limitation not contradict the above mentioned validation rule v5351_m, if the same limitation is not indicated in template F 06.01? The same problem occurs for validation rules v5350_m, v5353_m, v5725_m, v6054_m, v6055_m, v6056_m, v6057_m, v6058_m and v6059_m (FN2).Foot notes:FN 1: DPM table layout and data point categorisation updated 27 April 2017FN 2: Validation rules updated 08 December 2017 

  • 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: 2018_3670
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/10/2018