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List of Q&A's

Exempting foreign currency - denominated required minimum reserves according to Article 493(7) CRR

How is the level of exposures to central bank, in the form of Euro-denominated required minimum reserves in non-Euro Member States, determined for the purposes of Article 493(7) of Regulation (EU) No 575/2013 (CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3737
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Leverage ratio methodology - Art. 429(6) and (7) of Reg.(EU) No 575/2013 and Art. 429 a) of the Del. Reg. 2015/62 - art. 5 par. 3 of Comm. Deleg. Regulation (EU) 2015/63

To fill in some parts of the SRF 2018 Ex ante contributions Reporting forms in line with the Commission Delegated Regulation (EU) 2015/63, in particular the section related to “Derivative adjustment” (Art. 5 par 3), institutions must apply the “leverage ratio methodology” as defined in art. 429 of regulation 575 (CRR) to derivatives recognized in accordance with Article 295, where the current market value of the derivatives is negative. Are the variation margins paid in cash to the counterparty (a receivable asset) deductible from the net negative current market value (liability) of derivatives, based on the instructions contained in par. 3 of Article 429 a) of the delegated regulation 2015/62?

  • 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: 2018_3732
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

On demand secured lending of Level 1 assets

Can Level 1 assets that are used for on demand secured lending transactions be considered as liquid assets for the Liquidity buffer?

  • 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: 2018_3730
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Treatment of Value Added Tax (VAT) accounts opened for collection and payment of VAT

Should the Value Added Tax accounts be treated as operational deposits and should they receive the treatment mentioned at Article 27(1)(c) from Delegated Regulation (EU) 2015/61?

  • 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: 2018_3726
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 18/01/2019

COREP template C13: Consistency of the control v0530_m

COREP template C13: Is the EBA taxonomy control v0530_m consistent when tranches are deducted from own funds?

  • 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_3724
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

2.7 - Incorrect rules v0985_m and v0986_m

Validation rules v0985_m and v0986_m are incorrect in the taxonomy 2.7.0.1. They refer to columns 022 and 025 however these columns are greyed in the template F 20.04.

  • 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_3723
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/10/2018

Reporting of balances denominated in renminbi CNY and CNH in C22 MKR SA FX

In C22 MKR SA FX, where a bank is permitted to hold positions denominated in CNY and CNH, should CNH balances be combined with CNY balances in Row460, or included in Row470 under Other currency positions on the basis that CNH has its own readily-verifiable exchange rate and exposure against the reporting currency? For C22 Row020, if CNH balances are reported in Row470, should CNH be included in List of Closely correlated currencies against the Chinese Yuan (CNY) in Annex 1 to ITS ON CLOSELY CORRELATED CURRENCIES UNDER ARTICLE 354(3) OF REGULATION (EU) 575/2013?

  • 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_3720
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation Error arising from Guidance Notes for C 18.00 report

Which one should take precedence:(1) the general remarks for template C 18.00 in the ITS on Supervisory Reporting (Annex II), or(2) the existing formatting for the currency sheets of template C 18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3718
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Reporting of financial asset sales and write-offs in FINREP template F 02.00

How should financial asset (e.g. loan portfolio) sales and write-offs be reported in the template F 02.00 (Statement of profit or loss)?

  • 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_3716
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Fair value changes due to changes in cross-currency basis spread eligible for CET1 capital (cost of hedging)

Are fair value changes due to changes in cross-currency basis spreads recognized in ‘other comprehensive income’, as referred to under IFRS 9 as the ‘cost of hedging’, eligible for CET1 capital under the CRR regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3715
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

EBA COREP Validation Rules on C 05.01

Row 140 column 060 is required to have a value that is less than or equal to zero. That is specified by validation rule v5016_s. In addition, the value in row 140 column 060 includes data entered into row 380 col 060. Were the value in the latter cell entered as a large positive, it is possible that the resulting figure in row 140 column 060 would be positive. Should there be a constraint placed on the value in row 380 column 060?

  • 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_3709
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Validation rule v4792_m, C 12.00 - Securitisations

In C 12.00.a, the validation rule v4792_m is (r030;040;050;060;070;080;090)] {{c050}} <= {{c010}} Since row 30 (ORIGINATOR: TOTAL EXPOSURES) represents the totals for Originators, the above might not hold true in cases where significant early amortization exposures are present. This is because the row 100 for early amortization is greyed out for the columns 010 to 040 in the report template and hence is not considered in row 030 for these columns. However, row 100 is not greyed out for the column 050 where the validation check is applied.

  • 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_3705
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Question on CSD capital requirements and investment policy

For collateral to be considered of the best quality for the purpose of CSDR Articles 59(3)(d) and 59(4)(d), debt instruments are required to be liquidated “on a same day basis”. In the same manner, the appropriate timeframe in order to access the asset under the investment policy, as provided by art. 82(2), should be “on the same business day” We ask European Authorities to clarify the meaning of “same day basis” and “same business day” and the settlement period linked to it.

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2018_3704
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 28/01/2022

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