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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

Concept of “secured liabilities”

It is unclear whether the concept of “secured liabilities” as mentioned in Article 44(2)(b) BRRD covers liabilities benefitting from a State guarantee (including thus the so-called “GGBBs”) or whether it is limited to liabilities secured by assets (collateral)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3119
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Exercise of the power to convert liabilities towards creditors

For the purpose of resolution, may the resolution authority exercise the power to convert liabilities towards creditors that would not incur losses under normal insolvency proceedings, where the power of write down has previously been exercised to ensure that the net asset value of the institution under resolution is equal to zero? More generally, how can the needs for recapitalisation be met when the total amount of remaining liabilities which are not excluded or protected by NCWO is not sufficient and the total losses are lower than 8% of the total liabilities?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3118
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Purpose of the use of the power to write down and convert capital instruments and eligible liabilities

What is the purpose of the use of the power to write down and convert capital instruments and eligible liabilities in accordance with Article 59 of Directive 2014/59/EU (BRRD), in case of transfer of assets, right or liabilities to the bridge entity or the asset management vehicle or the use of the sale of business tool?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3117
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Conversion of eligible liabilities to equity

If it is not possible to convert bail-inable liabilities into equity, since, under the applicable national law, the institution may not have shareholders, would it be possible to recapitalize the institution only by writing-down relevant capital instruments and bail-inable liabilities, without converting any liabilities into equity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3116
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Principal amount in Articles 43-60

What does the term “principal amount” as referred to in Articles 43 to 63 of Directive 2014/59/EU (BRRD) refer to?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3115
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Deposits referred to the in Article 7(8) DGSD

Should the “deposits fulfilling a social purpose defined by national law, for which a third party has given a guarantee” referred to in Article 7(8) of Directive 2014/49/EU (DGSD) be considered as covered deposits or as a secured liability referred to in Article 43(2)(b) of Directive 2014/59/EU (BRRD) ? If not, what may be their ranking in insolvency proceedings referred to in Article 108 of BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3114
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

AST in combination with other resolution tools

What is the rationale for using the Asset Separation Tool in combination with other resolution tools?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3113
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Transfer of assets to an asset management vehicle

Can a bridge institution transfer assets to an asset management vehicle of its own accord, without the interference of the resolution authorities? Or can assets be transferred from the bridge institution to an asset management vehicle only if the resolution authorities exercise their power to transfer assets, in accordance with Article 42(1) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3112
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Minority Interests

In relation to the calculations mentioned in Article 81 CRR, does the information relating to a subsidiary have to be calculated before or after the consolidation process of that subsidiary in the group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3111
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/10/2017

Level of data to be reported for LEI codes provided in Annex I

For Template C 101.00, should we report position of the specific Low Default Counterparty mentioned in Annex I or also report position of the underlying organisations belonging to that Low Default Counterparty?

  • 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_3108
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Data level for template C 101.00 of Annex III related to Exposure Classes (column 020)

We notice that the same customer can fall into multiple exposure classes. How should we report such customer which has multiple exposure classes? Would it fall in one row with exposure class of the largest exposure or split exposure per exposure class in multiple rows?Example:There are customers in our dataset that could fall into 2 exposure classes being Corporate – Specialised Lending and Corporate – Other.How to treat such customers?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2017_3107
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification on Type of Facility to be used for Template C 102.00

How to interpret ‘short term’ for letters of credit mentioned in Option g) ‘Issued short-term letters of credit and other medium-low risk off-balance sheet items’?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2017_3105
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Repurchase Agreements in template F 08.01 versus assets encumbered in template F 15.00 – EBA validation v0912_m

Should we align the template F 08.01 and F 15.00 on repurchase agreement reporting?

  • 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_3101
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Market risk capital requirement for CIUs where a look-through approach is applied

Can the market risk capital requirement for CIUs where a look-through approach based on the underlying investments is applied be capped at the amount applicable if no look-through approach would be applied?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3099
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 12/05/2017

FinRep validation rules v3079_m and v3080_m

According to the validation rules v3079_m and v3080_m, the loans and receivables for Non-financial corporations of template F 06.00 have to be equal with the loans and receivables for Non-financial corporations of template F 18.00. It is explicitly stated that only DEBT INSTRUMENTS AT FAIR VALUE OTHER THAN HFT have to be reported in table F 18.00. However table F 06.00 includes all debt instruments including HFT. Therefore the validation rule cannot be run with the defined operator "=".

  • 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_3098
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Coins and banknotes in counterbalancing capacity ALMM

How should we report 'Coins and banknotes' in counterbalancing capacity sheet (C 71.00) of ALMM report?

  • 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_3097
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Risk weights for the core indicator set

EBA/GL/2015/10 Article 58, bullet point 2 suggests that there is no flexibility of the risk weights when the core risk indicator set are applied (with no additional indicators or any indicators left out). Would it be in compliance with the guidelines to use the core indicator set but to distribute the 25 % flexible weights somewhat different than what article 58, bullet point 2 suggests?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/10 - Guidelines on methods for calculating contributions to deposit guarantee schemes
  • ID: 2017_3096
  • Topic: Funding provisions (financing means, use of funds, borrowing, calculation of contributions)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Sliding scale method

We would prefer to apply the "sliding scale" method mentioned in EBA/GL/2015/10, but a strict interpretation of the methodology within the guidelines prevents the use of the whole defined scale.Would it be in compliance with the Guidelines to adjust the formulas in order to achieve ARW along the whole defined scale? And what adjustment would be preferable?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/10 - Guidelines on methods for calculating contributions to deposit guarantee schemes
  • ID: 2017_3095
  • Topic: Funding provisions (financing means, use of funds, borrowing, calculation of contributions)
  • Date of submission:
  • Published as final Q&A: 20/10/2017

What considutes a fair value of encumberred and non-encumberred asset for morgages on immovable property?

We would like to clarify what constitutes a fair value for the purpopse of encumbered and non-encumbered assets which are link to morgage of immovable property. What value should be used for the reporting of the Asset encumbrance template : Market Value (MV) or Mortgage plus interest. In addition tot this, should this amount be restricted to cover the balance of the exposure at the reference date . For example an exposure with an immovable propererty MV of €1million and a mortgage plus interest €850k and a balance of account of €840k; What amount should we report as Fair Value in the Template ?

  • 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_3094
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Own Credit Spread

Due to the endorsement of IFRS 9 for annual periods beginning before 1 January 2018, an entity may elect to early apply only the requirements for the presentation of gains and losses on financial liabilities designated as at fair value through profit or loss in paragraphs 5.7.1(c), 5.7.7–5.7.9, 7.2.14 and B5.7.5–B5.7.20 without applying the other requirements of IFRS 9. If an entity chooses to early apply those requirements it recognizes gains and losses on financial liabilities designated as at fair value through profit or loss in other comprehensive income instead of in P&L. Therefore, those gains and losses have to be reported in Template F 01.03. However, the taxonomy 2.5.01 for FinRep as at December 31st, 2016 does not yet include a separate row for this item. Where should gains and losses on financial liabilities designated as at fair value through profit or loss recognized in other comprehensive income be reported in template F 01.03 as at December 31st, 2016?

  • 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_3092
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017