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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

Tracking of Past-due amounts

In our view, the criterion “there is not, following the forbearance measures any past-due amount” must be met at the date when the exit criteria is examined (regardless whether there have been any past-due amounts before that date but after the extension of the forbearance measure). Do you agree?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2014_1016
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Performing FBE

In our view, “both” (not “either”) of the conditions a) and b) in paragraph 178 must be met. Do you agree?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2014_1015
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Entry criteria NPE for forborne exposures under probation

Entry criteria for NPE according to paragraph 179 are stricter than exit criteria according to paragraph 156. This can lead to an infinite circle of reclassifications.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2014_1014
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Accounting Scope of Consolidation

Do you agree that the term “within the accounting scope of consolidation” refers to the debtor’s accounting scope of consolidation? Do you agree that the group of connected clients according to large exposure methodology is an adequate approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1012
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 25/07/2014

Basel I floor

Instructions in Annex II regarding the required information about Basel I floor (Annex I, CA4, rows 870, 880, 890, 900) are not clear. For instance some guidance is needed on the required amount in rows 890/900 (80% or 100%)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1011
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/06/2015

Risks other than Delta for non-linear products

The EBA RTS 2013/13 on non-delta risk of options in the standardised market risk approach under Articles 329(3), 352(6) and 358(4) of Regulation (EU) No 575/2013 (CRR) proposes a scenario approach for non-delta risks. Interest rate spread options do not readily fit into the proposed scenario approach as the underlying interest rate applies to two date and the relative performance of each. How should the distinct underlying be constructed for this type of product?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 528/2014 - RTS on non-delta risk of options in the standardised market risk approach
  • ID: 2014_1008
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 12/09/2014

International organisations regarding z-axis "Country of residence of the counterparty"

Regarding the z-axis "Country of residence of the counterparty" within F20.04, F20.05, F20.06 and F20.07, please we would need to confirm whether international organisations should be considered individually (each and every of them with its own code, from The ISO code 3166-1-alpha-2), as it seems to be stated in question ID 2013_108 or, on the contrary, all of these exposures should be brought together and assigned to the geographical area "Other countries". This latter option is told in question ID 2013_143 referring COREP but also extending it to FINREP. In this case, which code should be assigned to "Other countries"? On the other hand, irrespective of the options, can multilateral banks be considered as "country" for this purpose, or it is just for the rest of international organisations? Thanks.

  • 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: 2014_1007
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

F18 & F19 Commercial Real Estate

Should we assume that the row "Commercial real estate" contains the same information as "Commercial immovable property", within F20.04? That is to say, does "Commercial real estate" request loans collateralized by commercial immovable property? Thank you very much.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1006
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/05/2015

Templates 17.1, 17.2 and 17.3 - Reconciliation between Accounting and CRR scope of consolidation

It is unclear from template 17 and the Annex V guidance whether template 17 should show either: (a) The difference between the accounting scope of consolidation and the CRR scope of consolidation, or (b) The balances as per the accounting scope of consolidation.

  • 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: 2014_1004
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Statement of Profit or Loss

1. What has to be included in 350 Other Operating Expenses and what in 380 Other Adminstrative Expenses? It is not clear what the difference between these two data points is, and to what extent we have the option to classify costs in one data point or the other. 2. Is it true that as long as in our judgement we consider a cost an operating cost, it should be included in 350 Other Operating Costs? 3. Are lessee costs, ie operating lease rentals, the only item we should be including or are required to include in data point 380 Other Administrative Expenses?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1002
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Statement of Profit or Loss

The guidance in Annex V for the Financial Assets Held for Trading data point, Annex V.Part 2.25 says that interest income - other assets "may include" interest income from balances at central banks and several other asset classes . Does this mean this is required, ie the balance "must include" interest income from balances at central banks and the other specified asset classes , or that this is optional?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1001
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/05/2015

Statement of profit or loss

Can you please clarify what is required by the Annex V guidance on this data point? Two parts of paragraph 24 (the reference given in the template) appear to be inconsistent. The phrase "May be reported" suggests that there is an option about whether or not to classify derivates Held For Trading in this data point, whereas "shall be included" suggests that the income and expense must be shown within interest income and expense, and therefore must be included in this data point 020 or data point 100 for any expense. Further, can you clarify how this paragraph 24 of Annex V relates to paragraph 21? Paragraph 24 is not given as a reference for this data point, but appears to be applicable as it applies to financial instruments Held For Trading. It strongly suggests that it is optional whether to include gains or losses from such instruments within Interest Income/ Expense or Gains and Losses. -------------

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1000
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/02/2015

Related party balances

Given that there is no specific guidance for where to classify Related Party balances in several templates eg 1.1, 1.2, 2.0, should Related Party balances be classifed on the nature of the underlying balance or transaction, e.g. Related Parties Loans and Advances within Loans and Advances?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_999
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/07/2015

FINREP Table 31 - Related parties - derecognition of non-financial assets

In Annex V in paragraph 2.122 it is stated that "this item should include the gains and losses on derecognition of non-financial assets, which have been generated by transactions with related parties". Further on it is stated in 2.122 a) that "gains or losses on derecognition of investements in subsidiaries, joint ventures and assiciates" should be included in this line item. (r070 in table 31.2). My question is therefore: If a financial institution sells a part of its shares (equity investemet) in a associate to a third party, is this considered as a non-financial asset, and hence a non-financial derecognition in the balance sheet?

  • 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: 2014_992
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Recognition of credit derivatives for protection buyer

An institution purchases protection through a credit derivative against an exposure. Is the exposure value for counterparty credit risk (CCR) for this derivative zero even if the derivative is either not eligible for credit risk mitigation or it is eligible but the institution abstains from using it for credit risk mitigation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_990
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 12/09/2014

FINREP Templates 8.1 and 8.2

Is FINREP template 8.2 a subset of FINREP template 8.1, or is it separate, and therefore the data should not be included within template 8.1?

  • 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: 2014_988
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 16/01/2015

LCR inflows/outflows for collateralised stock borrow/lend transactions within 30 day window

The LCR reporting templates for Outflows (C52) and Inflows (C53) do not include a section which allows firms to separate reverse-repo and other secured lending/borrowing transactions between those where collateral is re-hypothecated and those where collateral is not re-hypothecated, to cover the reporting institutions outright short positions. How should firms with matched book, fully collateralised stock borrow/stock lend transactions (which mature within 30 days) segregate these transactions from unmatched repo/reverse-repo transactions? The Basel III templates allow a 0% outflow/inflow in such cases (lines 289-295 and 264 of the Basel III implementation monitoring workbook), when the transaction matures in less than 30 days.

  • 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: 2014_987
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 31/07/2015

Treatment of Exposures to ‘Civil-law associations’

In case of exposures to 2 different partners belonging to a group of connected clients (A). and belonging at the same time to a civil low association (B), as required by the ITS, the exposure to the civil low shall be added to the exposure of each partner. In our example, do we have to add the total civil law exposure (B) (in case we cannot define the pro-quota) to both partners? In this case, when considering the exposure to the group (A) - in the template LE2 - we take two times the same exposure to the civil law.

  • 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: 2014_984
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 16/01/2015

Netting of DTAs and DTLs

1. For the purposes of netting DTAs and DTLs, Art. 38 (5) Regulation (EU) No 575/2013 (CRR) requires a pro rata allocation of DTLs between DTAs which are below the 10%-threshold mentioned in Art. 48 (1) (a) CRR and all other DTAs, which rely on future profitability. With this requirement, it seems that institutions are not permitted to net DTAs and DTLs before they enter into the threshold treatment (as the pro rata relation for the allocation of DTLs has to be fixed already based on those which are below the threshold), which seems to be different from the rules as set out in the Basel III framework. Could the EBA or the EU Commission confirm that Art. 38 (5) CRR indeed requires a different procedure for allocating DTLs to DTAs which rely on future profitability than the one set out in the Basel III text? 2. If the above understanding of the CRR text is confirmed, could the EBA or the EU Commission clarify whether the 10% basket mentioned in Art. 48 (1) CRR may only be filled with gross DTAs or whether an iterative calculation is permissible under the CRR? 3. If the suggested iterative calculation is permissible, we also seek clarification on how and at which point the proportion between the DTLs that may be allocated to DTAs related to temporary differences and those that may be allocated to other DTAs relying on future profitability is established. 3. If the suggested iterative calculation is permissi-ble, we also seek clarification on how and at which point the proportion between the DTLs that may be allocated to DTAs related to temporary differences and those that may be allocated to other DTAs relying on future profitability is established.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_980
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/06/2014

Definition of non-financial corporate credit and liquidity facilities.

Please could you clarify the definition of facilities offered to non-financial corporates to be reported in rows 1230 and 1240 of template 52?

  • 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: 2014_979
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 03/10/2014