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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

Definition of "hybrid contracts" in FINREP template F 08.01

What shall be considered a ‘hybrid contract’ for the purposes of reporting FINREP template F 08.01?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2017_3476
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Where to include nostro current account balances that Bank of Cyprus maintains with other credit institutions in LCR-Inflows (Template 74)

Where should we include nostro current account balances that Bank of Cyprus maintains with other credit institutions in Template 74 of LCR: in line 1.1.2.2.2 monies due from financial customers or 1.1.6 monies due from assets with an undefined contractual date?

  • 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: 2017_3475
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP F 12.1 Movements in allowances and provisions for credit losses

How shall the impact of transfers between impairment stages be reported in template F 12.1.?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2017_3474
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule e4901_n

Validation rule e4901_n (active as from DPM 2.6.0) states the following: [C 07.00.a (r140-170;190;210;220;250-280, c010-040;150-240, s014)] {C 07.00.a} = empty.We have values reported in C 07.00, s014, r140 relating to unsettled securities trades for which the contractual settlement date has not yet passed. As far as we are aware these trades do not attract a capital charge and we are reporting in on this line so as to show the exposure. Should these fields be left empty?

  • 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: 2017_3466
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Promise to pay and financial difficulties

If a customer misses a payment he or she can promise to pay the amount due in the same month (after we have contacted our customer). Should we define such a situation as a promise to pay or as a payment reminder? We have currently defined this situation as a promise to pay (‘Toezegging’ in Dutch), but that may diverge from the EBA perception of the associated risk with a promise to pay. As there have been several discussions on this topic with our supervisor we would appreciate EBA guidance. This should provide us with sufficient information to define this event in such a way that there can be no misinterpretations about meeting forbearance criteria.

  • 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: 2017_3463
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Validointissääntö e4900_n, C 07.00 Standardimenetelmän mukaiset pääomavaatimukset (Validation rule e4900_n: C 07.00 Capital requirements according to the standard method)

Original questionMillä lomakkeen C 07.00 rivillä ryhmän sisäiset katetut joukkovelkakirjat pitää ilmoittaa? English translationOn which row of form C 07.00 should intra-group covered bonds be indicated?

  • 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: 2017_3456
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/12/2017

Template C 17.00 (OPR Details) - Reporting on loss adjustments

How should we interpret and treat the negative loss adjustment within the total loss amount?How should we treat the total loss amounts compared to the top loss events and the max single 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: 2017_3455
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/12/2017

Calculation of general risk capital requirement for underwriting commitment regarding bond issuance and bond issuance programs under duration-based method specified in Article 340 of the CRR.

How should the capital requirement under duration-based calculation of general risk specified in Article 340 CRR be calculated where an institution is acting as an underwriter in bond issuance or bond issuance program? In particular, how to calculate the capital requirement before fixing of the coupon rate for bonds being issued and after that date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3450
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 19/01/2018

Amended validation rule v3693_s in v2.6

According to the amended validation rule column 060, row 010 of template C 05.01 should be reported as greater or equal to zero.On the other hand, the ITS sign convention states any amount that increases the own funds or the capital requirements shall be reported as a positive figure while any amount that reduces the total own funds or the capital requirements shall be reported as a negative figure.In our example given in ‘Background on the question’ box, row 010, column 060 (Total adjustments) represents net deductions and therefore is to be reported as negative. In fact in EBA Q&A 2015_2482 it states that those rows of column 060 which show deductions according to final provisions are reported with a negative sign.

  • 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: 2017_3441
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/12/2017

Foreign Exchange Risk– Off-balance sheet items in C 22.00

What should be included in row 110 “Off-balance sheet items” of template C 22.00 (MKR SA FX)?

  • 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: 2017_3437
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Disclosure of the difference between the fair value of a loan portfolio acquired/originated by a Bank and its contractual value

The fair value of a loan portfolio acquired/originated by a Bank differs from its contractual value. This difference (fair value adjustment on initial recognition (the “adjustment”)) has to be recognised in accordance with IFRS 3. In such case and since there is no separate column for this component, shall we reflect this adjustment in Template 4.4 row 170 ‘Loans and advances’ - under gross carrying amount (c010-c020) or under stock of provision (c030-c050)? We note that the issue of reporting this adjustment also arises on several templates which have no separate column for this component, namely F6, F7, F12, F20.4, F20.7, F18 and F19.

  • 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: 2017_3431
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Specialised Lending exposures

Could you confirm that Specialised lending exposures should not be reported in templates C 102.00 or C 103.00?

  • 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: 2017_3429
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Revolving exposures

Could you confirm that ‘Retail - qualifying revolving’ exposures should not be reported in the template C 103.00?

  • 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: 2017_3428
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Reporting requirements for template C 33.00

How shall exposures to entities that are classified differently between different reporting frameworks (i.e. FINREP and COREP) be assigned to an exposure class in Template C33?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3424
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Investment firms’ exposures to credit institutions

Should MIFID investment firms which are subject to the CRR calculate the credit risk requirement for the clients’ funds (i.e. cash) deposited in a credit institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3422
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Potential inconsistency between articles 68 and articles 69 through 71 in what concerns exemptions.

Considering contracts involving central counterparties and central banks are exempted from Member States' powers (i) "to suspend certain obligations" (69), (ii) "to restrict the enforcement of security interests" (70) and (iii) "to temporarily suspend termination rights" (71), are such organizations exempted from the "exclusion of certain contractual terms in early intervention and resolution" (68)? Example: if a crisis prevention measure is taken in relation to an entity with which a central counterparty or a central bank has a bilateral agreement, would the central counterparty or central bank be able to immediately exercise its contractual termination rights on the grounds of the referred intervention?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3421
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule (taxonomy 2.6) e4902_n about the risk weighted exposure for Equity in CR SA

Where shall equity exposures treated according to Articles 48(4), 471(2) and 495 (1) CRR be reported in COREP CR SA (C 07.00)?

  • 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: 2017_3414
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Reporting of assets credit-impaired at purchase within template F 04.03.1 and F 04.04.1

How shall row 190 (columns 015-070) within template 4.3.1 be filled in order to fully comply with, in our interpretation, contradictory attributes stated in the terms of both rows and columns?

  • 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: 2017_3410
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019