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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

Clarification of the relationship between EBA's Guidelines on outsourcing arrangements and Section 4 of the Directive (EU) 2015/849 - AML

Does the term of outsourcing (paragraphs 12 and 26) of EBA GL/2019/02 include performing of customer due diligence by third parties under Section 4 of the AMLD4, i.e. whether or not the application of GL/2019/02 to Performance by third parties would be in violation of the AMLD4?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5100
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 10/02/2023

Collection of fees for utilities or other regular services

Does a business model where the contributions (collected fees for utilities or other regular services) received from the payers are transferred to the payees (service providers) in individual transfers, without opening or maintaining accounts on behalf of neither payers nor payees (service providers), nor issuing any payment instruments to them, but the Company has contracts with the payees for accepting the transfers, constitute the provision of money remittance service as it is defined in Article 4(22) PSD2?Does a business model where the contributions (collected fees for utilities or other regular services) received from the payers are being aggregated and then transferred to the payee (service provider), without opening or maintaining accounts on behalf of neither payers nor payees (service providers), nor issuing any payment instruments to them, constitute the provision of money remittance service to the payer and acquiring of payment transactions service to the payee, as money remittance and acquiring of payment transactions are defined in Article 4(22) and (44) PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5099
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 06/01/2023

EBA validation rule v4859_m: [C 24.00 (c030;040;050;060)] {r100} <= {r030} + {r060} + {r080} + {r090}

The prevailing implementing technical standards (Commission Implementing Regulation (EU) No 680/2014 of 16th April 2014 as amended by Commission Implementing Regulation (EU) No 2018/1627 of 9th October 2018 provide guidance, about the breakdown of figures relevant for the calculation of market risk, when using internal models. In the Annex II point 5.7.1 - General Remarks, is stated: "142. Generally, the reporting depends on the structure of the model of the institutions whether they report the figures for general and specific risk separately or together. The same holds true for the decomposition of the VAR /Stress-Var into the risk categories (interest rate risk, equity risk, commodities risk and foreign exchange risk). An institution can resign to report the decompositions mentioned above if it proves that a reporting of these figures would be unduly burdensome". Considering that the separate reporting of specific and generic risk, for equity instruments, would be unduly burdensome and low material, it is not foreseen by the structure of the model applied, therefore we judge that total amounts for general and specific risk should be checked against total positions only. This feature has never been reviewed during the assessments and extensions of the model.

  • 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: 2020_5082
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Inconsistency in validation rule v4797_m COREP C14.00

Validation v4797_m states that [C 14.00 (All rows)] abs({c210}) &lt;= {c140}. The instructions in Annex II ITS "REPORTING ON OWN FUNDS AND OWN FUNDS REQUIREMENTS" for the completion of template C14.00, state that c130 "...the amount (according to original exposures pre conversion factors..", which corresponds to c010 to C 07.00 template. Additionally the instructions for c140 state to "...report the value of the securitised portfolio at reporting date...". Value in ITS is always net of value adjustments and provisions." Did we misinterpret the Annex II instructions? Please advise.

  • 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: 2020_5077
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

LCR treatment of liquidity inflows stemming from factoring

What is the LCR treatment of liquidity inflows stemming from factoring business?

  • 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: 2020_5075
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

Treatment of unfunded default fund contributions.

How should unfunded default fund contributions facing Qualifying and Non-qualifying CCPs be treated for leverage purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2020_5074
  • Topic: Leverage ratio
  • Date of submission:

Reporting of e-commerce card-based payment transactions falling within the scope of EBA Opinion EBA-Op-2019-06 for which no strong customer authentication was applied

Should e-commerce card-based payment transactions – falling within the scope of the EBA Opinion on the elements of strong customer authentication under PSD2 (EBA-Op-2019-06) and for which no strong customer authentication was applied – be reported under the higher-level category “Of which authenticated via non-strong customer authentication”?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
  • ID: 2020_5070
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Clarification of F 24.01, row 0310

What is expected to be reported in F 24.01, row 0310 ("Outflow of non-performing exposures that became non-performing during the period") as specified in paragraph 334 of Annex V, Part 2? Could you provide clarification on how to fill this row consistently with the instructions provided in paragraph 239iii of Annex V, Part 2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2019_5066
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Barrier options

Should barrier options also be seen as call and put options to which the standard supervisory delta formula as expressed in article 279c(1a) should be applied ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2019_5064
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Counterparty breakdown - classification based by immediate counterparty

What is definition of jointly incurred exposures for the purposes of FinREP (Annex V par. 43) ? Are there examples? Can guarantors be regarded as obligors and thus the exposures guaranteed by them as jointly incurred 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: 2019_5061
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

C 70 treatment of multiple currencies

If on the same day for one counterparty, funds in one currency are maturing and new funds are obtained in another currency, should these be treated as new funds or rollovers on the C 70 total template? In the case where the maturing deposit is replaced by more than one new deposit and both have different initial maturities, should the amount in rollover be proportionally spread across both time buckets?

  • 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: 2019_5058
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Implementation of the Article 12e(4) of Regulation EU 2019/876 (“CRR”) for subsidiaries that do not belong to the same resolution group as the EU parent institution.

Is it possible to adopt a reading of Article 12a and 92a CRR that would allow the application of the provision to subsidiaries established in third countries that are not included in a resolution group of the parent institution in line with point (83b)(iii) of Article 2(1) of Directive 2014/59/EU (“BRRD”)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_5057
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Data breakdown on fraud by different card functions for cash withdrawals

Does the breakdown on “card payments by fraud types” in Table E of the EBA Guidelines on fraud reporting under PSD2 refer only to cards with a credit/delayed debit function?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
  • ID: 2019_5056
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Contingency Measures under Article 33

Does fallback access to a secondary instance of the dedicated interface in a different data center with dedicated resources, provide an acceptable strategy and plan for the contingency mechanism?

  • 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: 2019_5054
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Short-term Exposures

What does short-term in this context mean? 90 days of remaining maturity or original maturity of 1 year?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_5053
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Exposure value according to Articles 247(5) and 249(2) CRR2 to be reported in C13.01 column 180

In the context of regulatory reporting of securitization positions under the new EBA regulatory reporting framework 2.9, the question regards the metric expected to be reported in the column [0180] EXPOSURE VALUE of template C13.01. On one hand, the supervisory reporting requirements on ITS under the framework 2.9 define the column [0180] EXPOSURE VALUE of template C13.01 as “Securitisation positions according to Article 248 of CRR”. The Article 248 of Regulation 2017/2401 states that the “exposure value of an on-balance sheet securitisation position shall be its accounting value remaining after any relevant specific credit risk adjustments on the securitisation position have been applied in accordance with Article 110”. As any reference to the application of credit risk mitigation is mentioned on the article 248, we conclude at the this point that the column [0180] EXPOSURE VALUE of template C13.01 should be the exposure value after specific credit risk adjustment after the application of CCF and before application of CRM. On the other hand, the Article 249(2) indicates that the exposure value subject to risk weights has to be after application of credit risk mitigation. However, in Article 247(5), the exposure value subject to risk weights is defined as the exposure value set out in Article 248. There is not a reference to the article 249(2) in article 247(5) or article 248. Could you please give the correct metric to report in column [0180] EXPOSURE VALUE of template C13.01 : is it the exposure value before or after the application of credit risk mitigations ?

  • 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: 2019_5048
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Recording of card payments

If a card has both an e-money and non e-money function, how should a payment be recorded? Should the recording be different based on the type of the reporting institution (for example, depending on whether is an electronic money institution (EMI) or a bank)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
  • ID: 2019_5046
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020