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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

Deduction of deferred tax assets

Regarding the phasing-in percentages established in Article 478(2) of the CRR, how should the deduction amount  be calculated during the transitional period when part of the stock of DTAs existed prior to 1 January 2014?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3224
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Supervisory Benchmarking - Alternative risk weight

How shall mortgage portfolios for which - based on Art. 230 (3) CRR when the conditions of Art. 199 (6) CRR are satisfied - an alternative risk weight (e.g. 50% for commercial real estate) is used, be reported in the benchmarking exercise. Or should these exposures where no PD or LGD estimation is available for regulatory purposes be exempted from the reporting.

  • 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_3222
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Undrawn uncommitted credit lines

What do we understand with "Undrawn uncommitted credit lines"? Are uncommited credit lines in the scope of the benchmarking? What kind of products are we talking about that fall into this category of facilities - are we talking about internal lines that have not been communicated to the customer? Are these relevant for COREP and the supervisory benchmarking?

  • 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_3221
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Validation Rule v3748_s partly incorrect

According to COMMISSION IMPLEMENTING REGULATION (EU) 2016/1702 of 18 August 2016 column 430 of Template ‘C 13.00 — CREDIT RISK – SECURITISATIONS (CR SEC IRB)’ has to be reported with negative values.Description: ‘ADJUSTMENT TO THE RISK-WEIGHTED EXPOSURE AMOUNT DUE TO MATURITY MISMATCHES: For maturity mismatches in synthetic securitisations RW*-RW(SP), as defined in Article 250 of CRR, shall be included, except in the case of tranches subject to a risk weighting of 1 250 % where the amount to be reported is zero. Note that RW(SP) not only includes the risk weighted exposure amounts reported under column 400 but also the risk weighted exposure amounts corresponding to exposures redistributed via outflows to other templates. Negative values shall be reported in this column.’Therefore column 430 should be excluded from validation Rule v3748_s.

  • 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_3220
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/07/2017

Scope of bail-in tool: Clarification on Article 44(2)(f)

Is the purchase or sale by an EU bank (falling within the EU Single Supervisory Mechanism) from/to a EU bank (also subjected to the EU Single Supervisory Mechanism) of a listed security (bond of equity) with settlement T+2 (up to T+6) through a clearer such as (but not limited to) Euroclear, Iberclear, Clearstream, Monte Titoli, Sicovam, etc... excluded from bail-in in force of Article 44(2)(f) of the Directive 2014/59/EU?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3219
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 01/12/2017

Mark-to-Market Method: Add-on for sold options

Should the PFE add-on for sold options that form part of a larger netting set exceed the maximum possible exposure increase of the netting that may result from the sold option?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3217
  • Topic: Market risk
  • Date of submission:

C 101.00 / C 102.00 – Calculation of exposure weighted CCF (c100)

Which exposure shall be taken into account for the calculation of the exposure weighted CCF?

  • 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_3216
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C 101.00 – Reporting of Rating (c040) - counterparties with multiple ratings

How shall the rating (column 040) be reported in template C 101.00, in case more than one rating applies to a certain counterparty?

  • 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_3215
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Meaning of “rate of conversion that severely dilutes existing holdings of shares or other instruments of ownership”

What is the exact meaning of “rate of conversion that severely dilutes existing holdings of shares or other instruments of ownership” in Article 47(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_3212
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Sequence of write down of shares and subordinated debt

When applying the bail-in tool, (but not the Point of Non-Viability write-down), is it necessary to act on all ”shares” before touching upon ”subordinated debt”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3211
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Sequence of bail-in and write down of capital

Are Articles 48 and 60 of Directive 2014/59/EU (BRRD) as well as Article 21 of Regulation (EU) No 806/2014 (SRM) conflicting with Articles 47 BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3210
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Conversion of bail-inable liabilities into other types of capital instruments

Should “bail-inable liabilities must be converted into shares or other types of capital instruments” in Article 46(1)(b) not state that bail-inable liabilities must be converted into shares and other instruments of ownership?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3209
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Particular wording used in Articles 45h(5)

Is the meaning of the wording used in Articles 45h(5), second subparagraph of Directive 2014/59/EU (BRRD) ("the resolution authorities responsible for subsidiaries on an individual basis") the same as the wording "resolution authorities of the subsidiaries" used in other articles of BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3208
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Eligible liabilities for the purpose of MREL

Can only eligible liabilities counting towards MREL be bailed in?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3207
  • Topic: MREL
  • Date of submission:

Interpretation of points (a) and (b) of Article 45a(1)

Do points (a) and (b) of Article 45a(1) state conditions for exemption from the MREL requirement for mortgage credit institutions financed by covered bonds? If so, how can resolution authorities verify these conditions beforehand?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3206
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Minimum requirements for own funds and eligible liabilities

Do all entities mentioned in Article 1(1) of Directive 2014/59/EU (BRRD) have to meet minimum requirements for own funds and eligible liabilities?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3205
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Risk weight of EURATOM debt

Which risk weight shall apply to outstanding/new EURATOM debt instruments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3204
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 14/07/2017

Definition of low default portfolios for 2017 supervisory benchmarking exercise: Missing Portfolio ID for exposures assigned to both the exposure class ‘institutions’ and to the sector of counterparty ‘general governments’

Which Portfolio ID should be used regarding the definition of low default portfolios (Annex I, C 102.00 Draft ITS) for exposures assigned to both(i) the exposure class ‘institutions’ in accordance with annex II, C 102.00, column 070 Draft ITS with reference to COREP and(ii) the sector of counterparty ‘general governments’ in accordance with annex II, C 102.00, column 080 Draft ITS with reference to FINREP?

  • 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_3201
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Annex I Template C101.00 - Sovereigns

Clarifications around which entities to include for those identified by a bloomberg ticker referencing a Sovereign

  • 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_3197
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Market risk capital treatment for third country CIU positions

For the purposes of Article 349 (F), which third country legislation may be considered to be equivalent to Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3195
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022