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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

Recognition for large exposure purposes of a guarantee granted by the central government on an equity exposure

Can an equity exposure guaranteed by a central government be exempted from the large exposure framework or can only debt instruments be exempted? In particular, would such guarantees be compliant with the eligibility requirement set in Article 213(1)(b) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3621
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 20/11/2020

Asset Encumbrance - Eligible collateral in a central bank

Should deposits at central banks be reported as central bank eligible assets?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3619
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 13/12/2019

IFRS 9, validation rule v1386_m

Validation v1386_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. {F 43.00, r070, c050} + {F 43.00, r070, c055} = xsum({F 20.05.b, c030, (r010-030, sNNN)}) Template 43 shall include reconciliation between the carrying amount of the item ‘Provisions’ at the beginning and end of the period by the nature of the movements, except provisions measured under IFRS 9 that shall instead be reported in template 12. In template 20.5, ‘Provisions for commitments and guarantees given’ shall include provisions measured under IAS 37, the credit losses of financial guarantees treated as insurance contracts under IFRS 4, and the provisions on loan commitments and financial guarantees under the impairment requirements of IFRS 9 and provisions for commitments and guarantees under national GAAP based on BAD in accordance with paragraphs 11 of this Part. Therefore template 20.5 can have a higher amount as template 43 and the validation rule can't be fulfilled.

  • 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_3618
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Interpretation of the term “commercial immovable property” especially “other commercial premises” for the application of the preferential risk weights for the risk weight assets purposes according to the Article 126 of the CRR.

What is the definition of “other commercial premises” as commercial immovable property in Article 126 CRR for the purposes of application of preferential risk weights for the risk weight assets purposes, if all other conditions stipulated in the CRR are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3615
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Market risk benchmarking – specification of portfolio 20

The specification for portfolio 20 includes shorting EUR 1 million per single-name 5-year CDS on 10 companies including ‘Unilever’. Should Unilever NV or Unilever PLC be used?

  • 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_3614
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Market risk benchmarking – specification of portfolio 15

The specification for portfolio 15 includes shorting EUR 2 million per single-name 5-year CDS on Italy, UK, Germany, France and USA (total EUR 10 million notional). What coupon rate should used for each country?

  • 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_3613
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Market risk benchmarking – specification of portfolio 12

The specification for portfolio 12 given in Section 2.2 of Annex 5 sets the initial spot price as ‘Level of USD/EUR on 12 October 2017’. Should London or New York closing time be used?

  • 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_3612
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Market risk benchmarking – specification of portfolio 10

The specification for portfolio 10 includes forward contracts purchased at the EUR/USD ECB reference rate as of EOD Oct 12, 2017. Are the forward contracts purchased at spot rate or forward rate (including fwd points)?

  • 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_3611
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

CAP for synthetic securitisations of originator institutions in STD based on Article 252

In case of originator institutions using the standardised approach (STD) having synthetic securitisations, is the CAP applied to all the securitised positions or only on the ones where the risk is retained?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3610
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

Weighted average risk weight calculation of the securitised exposures for an unrated securitisation position in STD according to Article 253

How shall the weighted average risk weight of the securitised exposures for an unrated securitisation position in the standardised approach (STD) be calculated? Has the average to be weighted on EAD before the conversion factor (EAD_pre_ccf) or on EAD?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3609
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

Reporting classification of exposures to regional governments and local authorities and public sector entities

For the purposes of populating C 07.00 and C 09.01 CoRep returns, should exposures to a regional government/local authority covered under Article 115(4) CRR or a public sector entity covered under Article 116(4) CRR be categorised for reporting as regional government/local authority and public sector entity exposures respectively (with column 240 reported as appropriate), or should they both be categorised as central government exposures?If reported as exposures to central government in C 07.00 and C 09.01 then for the purposes of populating the LE templates (C 27.00 etc) should the exposure be reported as one to the central government itself or to the specific named regional government/local authority, or public sector entity to which the exposure is incurred?

  • 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_3603
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of the interest income and interest expense from hedging derivatives

Our question is in which item of template F 02.00 (FINREP IFRS 9) interest income and interest expense from hedging derivatives classified in the category ”hedge accounting” should be reported, where:the hedging derivatives are used to hedge interest rate risk and are measured at fair value through profit or loss;the dirty price approach is the convention applied by the credit institution; andthe hedged instrument is not measured at fair value through profit or loss (i.e. the hedged instrument is a debt financial instrument whose interest is recognized as “interest income” or “interest expense” in the 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: 2017_3601
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

EBA validation rule v2708_m for DPM 2.6 and 2.7

In the latest version of Annex V of Finrep IFRS9, in the Part 1 paragraph 44 (h) “the immediate counterparties shall be for loan commitments, financial guarantees and other commitments received, the GUARANTOR or the COUNTERPARTY that has provided the commitment to the reporting institution” instead of the debtor of the loan. We would like to know whether this definition refers to all Finrep ITS’ templates or only to some of them. In particular, the use of the guarantor shall apply: • only to template 9.2 “Loan commitments, financial guarantees and other commitments received” or • to template # 9.2 “Loan commitments, financial guarantees and other commitments received”, template # 18 “Information on performing and non-performing exposures” and template # 19 “Information 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: 2017_3600
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Scope of application of the exemption from the cap on inflows in the Liquidity Coverage Ratio

Is it legally possible for a liquidity sub-group (as per Article 8 CRR) to apply for an increase in the cap on inflows from 75% to 90% (in accordance with Article 33(4) and Article 33(5) of LCR Commission Delegated Regulation (EU) 2015/61) only for the cash inflows generated by one institution in the liquidity sub-group?

  • 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_3598
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Template 17 for a financial conglomerate , that elects that none of its entities operating in the insurance sector apply IFRS 9 for financial years beginning before 2021.

How shall a financial conglomerate as defined in Article 2(14) of Directive 2002/87/EC which adopts the deferral of the application of IFRS 9 for its entities operating in the insurance sector (Article 2(8)(b) of the Directive) should fill in template 17 ‘Reconciliation between accounting and CRR scope of consolidation: Balance Sheet’ (in particular, templates F 17.01 and F 17.03), as both financial assets and financial liabilities of the controlled insurance companies will continue to be classified according to IAS 39 and not to IFRS 9?

  • 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_3596
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Low Credit Risk Template 4.4.1 and 4.3.1

Regarding the Column "of which: Instruments with low credit risk" detailed in the Template 4 series. Is there an expectation to have this populated by institutions which have not elected to adopted the practical expediency which IFRS 9 allows for the implementation of the new standard?

  • 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_3594
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Under Substitution Approach, How to report the covered part of the exposure where collateral is Covered Bond.

How shall the covered part of the exposure be reported where the collateral is a Covered Bond?

  • 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_3592
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

IFRS 9, validation rule v2776_m

Validation v2776_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. 

  • 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_3591
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Original Exposure value of Securities Financing Transactions calculated under Article 220 of Regulation (EU) No 575/2013 (CRR)

There appear to be differing interpretations within the industry on how to disclose the Original Exposure value in column 040 of template C 28.00. Some firms are reporting the fully adjusted exposure value as calculated under Article 220 of the CRR (E*). Other firms are including the gross asset value in Column 040 and making an adjustment for the associated collateral in column 300, thereby splitting the SFT transaction into its constituent parts. Can the EBA advise which is the correct treatment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements
  • ID: 2017_3590
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Retention bonus

Can an institution award retention bonuses to the management board in case of an intended IPO?

  • 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)
  • ID: 2017_3589
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 25/05/2018