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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

Deposits reported in P 01.02 and in P 02.01

This question aims to clarify the validation rule v4134_m of the Funding Plan template. This validation rule states that the total deposits reported under "P 02.01 - Insured and uninsured deposits" must be equal or smaller than the deposits reported on lines 020, 060 and 120 of the frame "P 01.02 - Liabilities". Due to several reporting issues we intend to clarify if the total deposits reported under "P 02.01 - Insured and uninsured deposits" only refer to retail deposits under the Article 411.2 of CRR

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2015_2425
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 03/02/2017

C105.02 / 010 - Portfolio ID

C105.02 / 010 - Portfolio ID. Is it possible to have multiple Portfolio IDs by model?

  • 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_2424
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C105.01 / 080 - Cure rate for defaulted assets

C105.01 / 080 - Cure rate for defaulted assets. Is this only applicable to the PD models?

  • 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_2423
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C105.01 / 050 - EAD weighted average default rate for calibration

C105.01 / 050 - EAD weighted average default rate for calibration. Is the specification only relevant to the PD models themselves? Also, does this mean the PD actually used for model build, or the latest monitored position?

  • 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_2421
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

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: