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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.

List of Q&A's

Exclusion of cash withdrawal services from PSD2

Is it a prerequisite for an ATM operator,to qualify for the exemption of article 3(o), to co-operate with a Payment Service Provider (authorised within the EEA or with a relative passport where necessasry) offering payment service number 2 of the Annex 1 of the PSD2?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Row 0820 of C 04.00

Row 0820 of C 04.00 - Own funds requirements related to Pillar II adjustments states that if a competent authority decides that an institution must calculate additional own funds requirements for Pillar II reasons, those additional own funds requirements shall be reported in this row. Two approaches could be considered:This row shall only be reported when Pillar II adjustments have been established as an amount instead of a ratio. This row shall always be reported:If Pillar II adjustments have been set as a ratio the amount to be reported is: P2R*RWA.If Pillar II adjustments have been set as an amount that figure shall be reported in row 0820 of C 04.00. Therefore, instructions do not establish which additional own funds requirements shall be reported.  Thus, which approach shall be followed to report row 0820 of C 04.00? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Funding plan - validation rule EBA_v08993

How can we solve a breach in the v08993_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities to be declared in P01.02 in line r145 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • 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

Funding plan - validation rule EBA_v08992

How can we solve a breach in the v08992_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities  to be declared in P01.02 in line r140 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • 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

Funding plan - validation rule EBA_v08991

How can we solve a breach in the v08991_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the deposits to be declared in P01.02 in line r130 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • 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

Funding plan validation rule EBA_v08990

How can we solve a breach in the v08990_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the deposits from non-financial corporations to be declared in P01.02 in line r060 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • 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

validation rule EBA_v08988

How can we solve a breach in the v08988_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the repurchase agreements  to be declared in P01.02 in line r010 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • 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

Maturity weighting of gross JTD amounts to calculate net JTD amounts

Are the maturity weighting of gross JTD amounts and three months floor of Art. 325x(3) applicable only to gross JTD amounts in cases where no offsetting is possible or are they applicable more generally to all gross JTD amounts?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Components included in total gross annual earnings used for the calculation of gender pay gap

Should overtime pay awarded to staff members be included in their total gross annual remuneration for the purposes of calculating the gender pay gap? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)

Collateral requirements for the ‚another credit protection‘ alternative in the form of cash on deposit held with a third-party credit institution

Does Article 26e (10) (b) of the Amended Securitisation Regulation allow cash collateral to be provided also in the form of a guarantee or letter of credit given by a qualifying third-party credit institution?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Calculation of the GAR and BTAR flow versus the previous disclosure period

For Small and Non Complex Institution and other institution, should the GAR and BTAR flow be calculated on a semi-annual or an annual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Definition of Stable Deposits in C73 Outflows

Can the EBA confirm, where customers who qualify for Transactional treatment under LCR delegated act, Article 24 1.b (ie are not captured by Article 25 Higher Outflows), with deposits held in a transactional account, ie a current account, but fail the activity criteria for Transactional accounts per Article 24 para 3 (salaries, income or transactions are regularly credited and debited respectively against that account), however pass the criteria for Established customer relationship (ie relationship >1 year), can these be treated as Stable with a 5% weighting?  Or Other with 10% weighting?

  • 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

Exposure to credit institutions in the form of derivative contracts

Should "exposure" also consider and include cash collateral held by the covered bond issuer from its swap counterparty? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).

The “Custody assets” referred in FINREP 22.2 is described as “services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”.  How should the word “Services” in the above definition be interpreted?  Does it mean to populate a balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee that is charged or revenue being generated? Extract from Annex V 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and other services provided by the institution shall be reported using the following definitions:  (a) ‘Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management. ‘Asset management’ shall be reported by type of customer: collective investment undertakings, pension funds, customer portfolios managed on a discretionary basis, and other investment vehicles;  (b) ‘Custody assets’ shall refer to the services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management. ‘Custody assets’ shall be reported by type of customers for which the institution is holding the assets distinguishing between collective investment undertakings and others. The item ‘of which: entrusted to other entities’ shall refer to the amount of assets included in custody assets for which the institution has given the effective custody to other entities;   As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSII is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Sign Convention and aggregated rows in Template 2 of the ITS on IRRBB

Could the EBA please clarify the expected sign convention for columns 0040 to 0090 and 0110 to 0120, and the aggregation logic for rows 0540 to 0560 in template J 02.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Application of article 378 for free delivery transactions

Given the requirements of article 378 and 379 CRR II, shall the institution apply the article 378 also in case of free deliveries (disciplined by article 379) or should it be applied only to DVP transactions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of "Communication Standards" under Article 30.3

a) Is ISO 20022 considered the communication standard referenced in Article 30(3) of the Regulatory Technical Standards (RTS), Commission Delegated Regulation (EU) 2018/389? b) How should NCAs ensure that ASPSPs comply with these standards, in accordance with Article 30.6 of the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Reporting of deferred tax assets on the C33.00 - Exposures to General governments template

CRR article 48 (4) requires deferred tax assets that are dependent on future profitability and arise from temporary differences (DTAs) that are not deducted from capital to be risk weighted at 250%. EBA Q&A 2013_390 clarifies that ‘net deferred tax assets which depend on future profitability and arise from temporary differences (DTAs) and which are risk weighted with 250% according to Article 48 (4) of Regulation (EU) No. 575/2013 (CRR) are assigned to the exposure class of the obligor’. ANNEX II – Reporting on Own Funds and Own Funds Requirements states that exposures risk weighted in accordance with Title II of Part Three CRR (Credit risk framework) should be included on the C33.00 - Exposures to General governments template (C33). However, DTAs are risk weighted under the ‘Own Funds and Eligible Liabilities’ section. In cases where DTAs are exposures to governments, should these be included on the C33.00 - Exposures to General governments template (C33) in column 290 and 300?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Providing payment service via Internet banking (web-application)

Is providing payment service via Internet banking (web-application) payment initiation channel considered to be issuing of payment instruments? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/09 - Guidelines on authorisation and registration under PSD2