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List of Q&A's

EBA COREP Validation Rules on C 05.01

Row 140 column 060 is required to have a value that is less than or equal to zero. That is specified by validation rule v5016_s. In addition, the value in row 140 column 060 includes data entered into row 380 col 060. Were the value in the latter cell entered as a large positive, it is possible that the resulting figure in row 140 column 060 would be positive. Should there be a constraint placed on the value in row 380 column 060?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2018_3709
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Validation rule v4792_m, C 12.00 - Securitisations

In C 12.00.a, the validation rule v4792_m is (r030;040;050;060;070;080;090)] {{c050}} <= {{c010}} Since row 30 (ORIGINATOR: TOTAL EXPOSURES) represents the totals for Originators, the above might not hold true in cases where significant early amortization exposures are present. This is because the row 100 for early amortization is greyed out for the columns 010 to 040 in the report template and hence is not considered in row 030 for these columns. However, row 100 is not greyed out for the column 050 where the validation check is applied.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2018_3705
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Question on CSD capital requirements and investment policy

For collateral to be considered of the best quality for the purpose of CSDR Articles 59(3)(d) and 59(4)(d), debt instruments are required to be liquidated “on a same day basis”. In the same manner, the appropriate timeframe in order to access the asset under the investment policy, as provided by art. 82(2), should be “on the same business day” We ask European Authorities to clarify the meaning of “same day basis” and “same business day” and the settlement period linked to it.

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2018_3704
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 28/01/2022

Reference to Chapter III in Article 96(3)(b)

Is the reference to Chapter III in Article 96(3)(b) correct?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3703
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Enforce a third country resolution proceeding

How should the outcome under Article 94(4)(d) be achieved and in what way is that article different from the provision under Article 68?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3702
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Clarification on the authority responsible for the DGS

Which exactly is the authority responsible for the DGS referred to in Article 88?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3701
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Other groups or colleges in Articles 88(6) and 89(4)

Could you please explain what “other groups or colleges” can carry out the work assigned to the resolution colleges with regard to Articles 88(6) and 89(4)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3700
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Intervention of the resolution fund to cover for losses due to creditors / liabilities excluded from bail-in

Can Article 101(2) of Directive 2014/59/EU (BRRD) be interpreted in the way that even if all bail-inable creditors have been subjected to bail-in and losses are still not covered, a bridge bank would not be allowed to take on the remaining losses and thus resolution would not be possible?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3699
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Clarification regarding the consideration in Article 42(6)

Can you please clarify Article 42(6) of Directive 2014/59/EU (BRRD); regarding that the consideration can have a nominal or negative value? Does effect of this mean that the asset management vehicle (AMV) must owe a debt to the institution under resolution?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3698
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Valuation in Article 36

How should the resolution authority perform the valuation mentioned in Article 36 of Directive 2014/59/EU (BRRD) before making the decision initiating resolution if it is not entitled to require certain information from the particular entity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3697
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Conditions for Early intervention

What are the conditions for Early intervention in Article 27(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: 2018_3696
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 09/03/2018

Definition of 'explicit guarantee arrangements' for the purpose of classification of non-commercial undertakings as public sector entities

What conditions should be met by a given agreement in order to qualify as an 'explicit guarantee arrangement'?Shall the ‘explicit guarantee arrangements’ for the purpose of definition of public sector entities also be ‘guarantees’ eligible as unfunded credit protection or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3694
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule v_1044_m (FINREP template 16.3 IFRS9)

The validation rule v1044_m requires that for template F 16.03 the following condition is fulfilled: {r090} = sum(r010-080).However, in taxonomy v2.7 template F 16.03 has been amended: row 015 (of which: Economic hedges with use of the fair value option) has been added. Is the validation rule v1044_m still valid?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3692
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Reporting reference dates for template C 33.00

Could you please confirm what the first reporting reference date for the sovereign exposures template (C 33.00) for institutionsi. who report on a calendar year basis (i.e. accounting reference date 31 Dec)ii. whose accounting reference date deviates from the calendar year (say 31 March) and are permitted to apply Article 2(3) of Regulation (EU) No 680/2014is?

  • 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: 2018_3691
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template

How should (banking) holidays and weekends be reflected in C 70.00 (zeros, empty lines or constant volumes)? How should an internationally active credit institution with subsidiaries in different countries reflect holidays in different countries and working days in the weekend? Is there a different approach to be taken for non-maturity funding versus term funding in light of weekends and (banking) holidays?

  • 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: 2018_3689
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Annexes I & II, C 18.00, validation rules v4850_m and v4851_m.

Is there an error in the validation rules v4850_m and v4851_m applicable to template C 18.00? 

  • 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: 2018_3682
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Committed liquidity facilities to a special purpose vehicle (SPV)

Figure 4.1.2 of ANNEX XIII clearly refers to Article 31 or Regulation (EU) 2015/61, which is the regulatory basis of the LCR. According to Article 31 committed liquidity facilities to SPVs which have a maturity date above 30 days are not considered within the Outflows. Therefore we would not consider these cash flows in row 1130. Row 1090 has no reference to Art. 31 of the LCR and it states the requirement '[...] the maximum amount that can be drawn in a given time period'. Is it correct to show above mentioned cash flows only in row 1090?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3681
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Validation rule v5053_m in DPM 2.7.0.1

For all rows in template F12.01a the validation v5053_m states: {c100} = sum(c010-090). Is it correct that including row 350 (of which: non-performing) is an error in validation v5053_m?

  • 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: 2018_3680
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Impact of a profit and loss transfer agreement under German company law on the eligibility of CET1 instruments for subsidiaries having full discretion on contributing common equity tier 1 capital as defined in Article 26 of the CRR

According to Q&A 408, an agreement an institution has entered into with its 100% parent entity, pursuant to which the institution must transfer its profit for the period to the parent entity (and the parent entity must cover any losses) constitutes an obligation to distribute (mandatory distribution), which is not permitted under Article 28(1)(h)(v) of the CRR. Is the case different where the institution is free to decide to set aside reserves from profits generated, according to its own commercial judgement or discretion, hence avoiding a profit transfer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3675
  • Topic: Own funds
  • Date of submission: