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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

Provision of data to cover the cost of living

Does the data referred to in Article 8(4) DGSD have to be provided by the credit institution after the date on which the credit institution has become unable to repay deposits? Or is it possible for a DGS to use data which has been provided by the credit institution before the credit institution has become unable to repay? If DGS are expected to use data which is provided after the aforementioned date, does the data have to be provided specifically for calculating the appropriate amount or can/must data be used which is (mainly) provided for making the repayments?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2907
  • Topic: Rights of depositors (Eligibility, coverage level, repayable amount, repayment, claim against DGS, depositor information)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Minimum requirement for own funds and eligible liabilities (MREL) - procedures, forms and templates

1. Will the MREL-reporting template for all institutions (not just those overseen by the SRB) be based on the SRB’s current LDT rather than Annex V of the EBA final draft ITS on resolution plans?2. Will electronic data delivery be in the form of XBRL?3. Will the templates and electronic format be published in 2016?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2906
  • Topic: MREL
  • Date of submission:

Clarification of 'Facility Type', regarding the characteristic values 'Other Facilities' (Annex I) and 'Full Risk' (Annex II)

The segmentation criterion 'Facility Type' is used to define the benchmarking portfolios. In Annex I, Template C 102.00 (Definition of Low Default Portfolios), for some portfolios the facility type is 'other facilities'.The characteristic value 'other facilities' is not defined in Annex II. However, in Annex II, Template 102, 'full risk' is a characteristic value for the segmentation criterion 'Facility Type'.'Full risk' is not used in Annex I. Is it correct to assign 'full risk' to 'other facilities' and if yes, is it correct to only assign 'full risk' to 'other facilities'?

  • 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: 2016_2902
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification of 'Facility Type', regarding the characteristic values 'Undrawn committed credit facility' (Annex I) and 'Undrawn committed other credit facility' (Annex II)

The segmentation criterion 'Facility Type' is used to define the benchmarking portfolios. In Annex I, Template C 102.00 (Definition of Low Default Portfolios), for some portfolios the facility type is 'Undrawn committed credit facility'. The characteristic value 'Undrawn committed credit facility' is not defined in Annex II. However, in Annex II, Template 102, 'Undrawn committed other credit facility' is a characteristic value for the segmentation criterion 'Facility Type'. 'Undrawn committed other credit facility' is not used in Annex I. Is it correct to assign 'Undrawn committed other credit facility' to 'Undrawn committed credit facility' and if yes, is it correct to only assign 'Undrawn committed other credit facility' to 'Undrawn committed credit facility'?

  • 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: 2016_2901
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Which amount should be reported in template C 22.00, column 020 and 030 - all positions?

According to Regulation 680/2014 (ITS Supervisory reporting) - Annex II , institutions should report in template C 22.00, column 020 and 030 all gross long and short positions due to assets, amounts to be received and similar items referred to CRR article 352 (1).When an institution (reporting currency EUR) enters into a foreign exchange Forward, e.g. sell USD (notional EUR 100, Present value EUR -95) and buy GBP (notional EUR 100, present value 100), which value should be reported in columns 020 and 030?Should it be:a) notional position: long GBP (EUR 100) and short USD (EUR 100)b) present value of the notional positions: long GBP (EUR 100), short USD (EUR 95)c) present value of the notional positions: long GBP (EUR 100), long USD (EUR -95)

  • 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: 2016_2900
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

FINREP Taxonomy 2.5 Templates 04.04/18.00.b Validations

In taxonomy 2.5, are validations v3049_m to v3076_m the correct way round? That is, should the “<=” sign be “>=”?

  • 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: 2016_2899
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Eligible asset classification for counterbalancing capacity C 71.00 – Concentration of Counterbalancing capacity by issuer / counterparty

Should items such assenior bonds and deposits on current accounts with other credit institutions orshares of UCITS, which qualify as Liquid Assets for the LCR-Reportingbe reported in template C 71.00 – Concentration of Counterbalancing capacity by issuer/counterparty?

  • 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: 2016_2897
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/03/2018

SA securitisation framework – calculation of the concentration ratio

Should the concentration ratio defined in Article 253(2) CRR be adjusted as securitisation tranches amortise or are written off over time?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2895
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Obligation to carry out analysis and to consult with EBA on planned increase of risk weights before RTS on this matter are finally adopted and published in the Official Journal of the European Union

Is there an obligation to carry out appropriate analysis and to consult with EBA on planned increase of risk weights since RTS on this matter are not finally adopted and published in the Official Journal of the European Union?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2894
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/02/2017

Clarification of columns 050 and 060 of template C 101.00, Annex I of the Benchmarking exercise.

In ITS-Annex I of the Benchmarking exercise the columns 050 and 060 provide the ISIN code and Bloomberg ticker, respectively. Is the requirement to report only exposures to the instruments specified by the ISIN/Bloomberg ticker or should all exposures to the counterparty be reported?

  • 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: 2016_2892
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Standardised approach risk weighting

In the scenario below, if the repayment of a retail depends on the client's business (and not the performance of the property), could a loan secured by immovable commercial property have a higher RW than a similar loan which is unsecured?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2891
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Seeking clarifications/ remediation on EBA LCR specified taxonomy mapping for Annex XXIV and Annex XXV templates

We have identified a taxonomy anomaly in the EBA LCR 70s Series taxonomy that does not allow for this guidance to be implemented for collateral swaps. Unlike template C 73.00 where ‘counterparty is central bank’ shows a 0% standard weight resulting in a 0 outflow (C 73.00, r930 c040 – c060), template C 75.00 does not provide a specific row to delineate exposure to central banks. Therefore it is not possible to isolate collateral swaps with a central bank to apply 0% outflows in the current template and taxonomy construct as per guidance - Article 28.4 of Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement: ‘Collateral swaps that mature within the next 30 days shall lead to an outflow for the excess liquidity value of the asset borrowed compared to the liquidity value of the asset lent unless the counterparty is a central bank in which case a 0% outflow shall apply’.

  • 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: 2016_2890
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reporting of of the group of connected clients in C27 Identification of the counterparty (LE1) when the national reporting system DOES NOT provide a unique code for the group of connected clients

It is unclear if the group of connected clients should be reported in C27 Identification of the counterparty (LE1) when the national reporting system DOES NOT provide a unique code for the group of connected clients.

  • 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: 2016_2888
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting of collective allowances for incurred but not reported losses on non-performing exposures in FINREP F 18.00 and F 19.00 templates

If incurred but not reported losses (IBNR losses) relate to a non-performing exposure, in which column should the collective allowances for IBNR losses be reported in template F 18.00 and F 19.00?

  • 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: 2016_2887
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Transactions with maturities longer than 10 years

We reference to the Q&A 2015_1802: Transactions with maturities longer than 10 years are excluded in the form C 69.00. Does the excluding of transactions with maturities longer than 10 years also apply for the form C 70.00?

  • 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: 2016_2885
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 01/12/2017

Distribution by an originator to its shareholders of a participation instrument the pay out of which is directly linked to the net cash flows under the net economic interest retained

Would a credit institution acting as originator in relation to a securitisation and holding the net economic interest pursuant to Article 6 Regulation 2017/2402 be in breach of Article 12 of Regulation (EU) 625/2014 if such credit institution decides to issue to its shareholders, free of charge, a participation instrument the pay out of which is directly linked to the net cash flows under the net economic interest retained by the originator?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 625/2014 - RTS on requirements for investor, sponsor, original lenders and originator institutions of transferred credit risk exposures
  • ID: 2016_2878
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 17/02/2017

Is a tied agent of the investment firm a financial institution and should it be included in prudential consolidation

1. Should a company acting as a tied agent of the investment firm be included in prudential consolidation according to Art. 18 of CRR, if the tied agent is controlled by the same holding company as the investment firm (or by the investment firm itself)? 2. Should the company acting as a tied agent be included in the prudential consolidation a) because it is an ancillary services undertaking in accordance with Art. 4(1) point 18 of CRR, b) because it is a financial institution in accordance with Art. 4 (1) point 26 of CRR, or c) because of some other justification to require the consolidation, or d) should it not be consolidated at all in accordance with Art. 18(1) nor (8) of CRR.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2875
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

COREP C 17.00 - operational risk / losses to be reported

In COREP C 17.00, is there a definition of which losses have to be reported related to usury and compound interest? Our bank also includes losses here that are linked to credit risk (to be more specific: fraud linked to credit risk). Although fraud is indeed covered by COREP C 17.00, we understand the underlying rules of COREP C 17.00 to be "operational losses only". However, we are unsure what the correct interpretation of "operational losses" is here. For the determination of capital requirements, should these credit-risk related fraud losses be captured within the operational risk (so COREP C 17.00) or within the credit risk?

  • 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: 2016_2874
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Contributions to the financing arrangements from ceased banks

Do institutions that cease to exist or to be supervised in a given year prior to the determination or raising of the annual contributions still have to contribute to the financing arrangements?

  • 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: 2016_2872
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Cap on inflows for consumer finance or leasing and factoring activity

When a bank constituting a single liquidity subgroup is applying for a preferential treatment in accordance with Article 33(3) or Article 33(4) of the LCR Commission Delegated Regulation (EU) 2015/61 at consolidated level, does Article 33(5)(b) of the LCR Commission Delegated Regulation (EU) 2015/61 refer to the balance sheet value of the individual entities or to the consolidated single liquidity sub-group?Also, when assessing a request in accordance with Article 33(3) or Article 33(4) of the LCR Commission Delegated Regulation (EU) 2015/61 at individual level, is it possible to exclude some components of the total balance sheet when checking if the ratio ‘activities as referred to in Article 33(3) over total activity’ or ‘activities as referred to in Article 33(4) over total activity’ exceeds 80% of the total balance sheet (e.g. shareholdings in subsidiaries performing the same activity, refinancing agreements toward these subsidiaries)?

  • 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: 2016_2870
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 14/07/2017