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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.

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List of Q&A's

Treatment of an institution’s investments into EU AIF managed by a non-EU AIFM and into closed-ended CIUs

Should not the investment of an institution into a closed-ended CIU which has been marketed in accordance with Article 42 of AIFMD, but is not marketed anymore due to the end of its marketing phase, remain eligible to apply the look-through to the underlying exposures of the CIU, provided the other relevant conditions for looking-through continue to be met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6057
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Asset encumbrance in the NSFR

How to determine the residual maturity of the encumbrance in a cover pool if it derives from covered bonds with different maturity?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6055
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Legitimacy of the suspension of the accounts of one or more users by the owner of a digital platform, upon request of an obliged entity, due to suspicious transactions executed on the digital platform.

If a payment institution detects that several suspicious payment transactions have been executed or are to be executed on a digital platform and requests the owner of such platform to suspend the accounts of the users who have initiated such suspicious transactions, should the owner of the digital platform be exonerated for any liability due to the suspension of such users’ accounts?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6054
  • Topic: Suspicious Transaction Reporting
  • Date of submission:

Calculation of past due days

a. Shoud materiality threshold be used in a Template 7.01? b. If in a Template 7.01 materiality threshold shouldn't be used, can we have for same exposure differently reported past due time buckets in templates 7.01 and 18.00?

  • 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
  • ID: 2021_6050
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

PISP obligations to conduct CDD

In the case where the Payment Initiation Service Provider (PISP) has a business relationship as defined under Article 3(13) of Directive (EU) 2015/849 (AMLD) with the payee, and not with the payer, would it still be considered an occasional transaction for the payer, as the service is provided as a single transaction for the initiation of a payment order from the account that belongs to the payer? 

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/02 - Guidelines on customer due diligence and the factors institutions should consider when assessing the ML /TF risk associated with individual business relationships and occasional transactions under Articles 17 and 18(4) of AMLD
  • ID: 2021_6048
  • Topic: Customer Due Diligence
  • Date of submission:
  • Published as final Q&A: 17/03/2023

Validation Rules v6205_m and v6206 in respect of portfolios with only Unfunded Credit Protection

How the two blocking Validation Rules v6205_m and v6206_m in current DPM, applicable to Supervisory Benchmarking reporting, shall be managed in light of the regulatory provisions of Article 158(5) of Regulation EU 575-2013 (CRR) allowing portfolios to have Expected Loss equal to zero and PD, LGD, EAD all greater than zero?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_6047
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Calculation of NPV loss in case of (internal) refinancing

Which NPV loss should be taken in order to calculate the NPV loss if the 1% threshold is breached and the forborne loan contract should be placed in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2021_6045
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Re-engineering by TPP of the ASPSP’s redirect API and PSU customer journey

May a Payment Initiation Services Provider (PISP) connect to the dedicated interface of the ASPSP, only to subsequently embed (“screen scrape”) the redirection approach into their own environment, without redirecting the PSU to the ASPSP’s mobile banking app, for authentication?  Are Third-Party Providers (TPPs) allowed to re-engineer the customer journey designed by the ASPSP to the effect that authentication of the PSU will take place in the TPP domain?

  • 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
  • ID: 2021_6044
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 13/04/2022

Template F 12.1a

F12.1a – Movements in allowance and provisions for credit losses The EBA has introduced a new section for ‘Allowances for purchased or originated credit-impaired financial assets’ (row references r600-r750) with granular sub-sections for ‘Debt Securities’ and ‘Loans and Advances’, broken down by industry classification. This new section has the existing column for ‘Increases due to origination and acquisition’ (column reference c020) greyed out: This greying out of column c020 means that no data can go into the column for the Purchased / Originated Credit Impaired Assets. We believe this is an error in the design of the template as a bank, if we were to procure credit impaired financial assets from an outside third party or to write credit impaired facilities to potential new / existing customers, we would expect to report these balances against column c020 ‘Increases due to origination and acquisition’. Can you please share your thoughts in terms of the rationale behind blocking c020 for the POCI rows r600-r750 and advise how we should proceed in the event we have to report these balances in future submissions?  

  • 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
  • ID: 2021_6043
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Reporting of IRB exposures in the form of units or shares in Collective Investment Undertakings (CIUs) treated under the Fall-Back Approach (FBA)

When applying the credit risk IRB approach, in which template and field shall institutions report exposures in the form of units or shares in CIUs treated under the new FBA (pursuant to Article 152(6) CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_6040
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

Reduction of own funds according to Article 78(1)(a) CRR

May an institution that intends to reclassify part of its share capital as related share premium apply for the prior permission pursuant to letter (a) of Article 78(1) CRR or should letter (b) be used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6039
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/11/2022

DPM 3.0 - C80.00 - C84.00 - Inconsistent modelisation and validation rules v10127_m and v10143_m.

Modelisation issue between report C80.00 and C84.00 but only for the sheets giving a breakdown per currency as we have some inconsistent duplicated fact. See background on the question.

  • 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
  • ID: 2021_6038
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 23/07/2021

Template F 22.02: Assets involved in the services provided

Third party investment products distributed by an institution should be reported under “Assets Management” (F 22.02, r0010, c0010), “Custody Assets” (F 22.02, r0060, c0010) or “Customer resources distributed but not managed” (F 22.02, r0130, c0010)?

  • 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
  • ID: 2021_6036
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Reporting of Securitisation Exposures in Template C43.00

Since the introduction of the new prudential requirements for securitisation exposures under Regulation 2017 2401, there is only one reporting template used for securitisation exposures as a result of the Basel III changes i.e. all securitisation exposures are now reported in a single COREP template C13.01 and there is no split between IRB and SA securitisation exposures. However, for reporting the breakdown of the components of the Leverage Ratio exposure measure in template C43.00, there is still a split required between the SA and IRB securitisation exposures and RWEAs in row 0300, columns 0010-0040. Pending future amendments to template C43.00, can we confirm if banks should now exclusively use the SA columns 0010 and 0030 of C43.00 to report all their securitisation exposures or should the split between SA and IRB exposures be retained?

  • 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
  • ID: 2021_6034
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Reduction, distribution and reclassification of share premium accounts related to own funds instruments

May an institution announce to the holders of own funds instruments the reduction, distribution or reclassification of related share premium accounts before that institution has obtained the prior permission of the competent authority foreseen under Article 77(1)(b) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2021_6031
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Scope of “additional registrations” as obstacles in the sense of Article 32(3) Delegated Regulation (EU) 2018/389

Is a process that requires Third Party Providers (TPPs) to upload an electronic IDentification, Authentication and trust Services (eIDAS) certificate for receiving additional client credentials before first access to a payment account provided by an Account Servicing Payment Service Provider (ASPSP) to be considered an “additional registration” and therefore an obstacle?

  • 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
  • ID: 2021_6029
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Definition of "accounting value" for the purpose of template C 80.00

Should the assets, except for the derivatives contracts,  be presented in template C 80 from Regulation (EU) 451/2021 as gross accounting value (not affected by  general and specific allowances) or as net (affected by  general and specific allowances)? 

  • 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
  • ID: 2021_6026
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Calculation of the relative threshold in case specific cases.

How should be calculated the relative threshold for a client who has fees or quotes in default arising from off balance sheet exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/171 - RTS on the materiality threshold for credit obligations past due
  • ID: 2021_6025
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/04/2023

ValidationRule v11073_i

According to this validation rule v11073_i, the sheet's I 01.00 row 0090 C 0010 should be equal to the row 160 c0010 of the template C 01.00. In our opinion this VR should not be satisfied because the  row 0090 C 0010 is referred to the "Accumulated other comprehensive income" which is different from the  row 160 c0010  of the Corep "Profit or loss attributable to owners of the parent". These two cells have the same DPVID but the regulatory norms are differents. In the Corep the information about the "Accumulated other comprehensive income"  is reported in the row 180 instead of 160.  Looking also at the Annex of these two rows, it's possible to observe that  the article of the row 180 is the same  of the row 0090 C 0010 of I 01.00, both in fact refer to the Article 26(1), point (d) of CRR. Instead, the row 160 refers to another article, Articles 26(2) and 36(1) point (a) of CRR.   

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6024
  • Topic: Supervisory Reporting - IFR Reporting framework
  • Date of submission:
  • Published as Rejected Q&A: 14/02/2022