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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

Dynamic Linking for batch payments

With regards to dynamic linking for a batch of remote electronic payments, should the authentication code be linked to each and every IBAN of all the beneficiaries in a batch file?

  • 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: 2018_4435
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

[eba_v1042_m] f16.01

Why the total of the table F16.01.b doesn't follow the rule [eba_v1042_m]? Is this related to negative interest rates?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4434
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Operational Risk business line mapping

When an entity carries out an activity for retail customers in a supportive manner to lending and taking deposits from customers in such a way that the entity has neither a separate organisational unit nor a specific internal P/L account for this activity, should it be allocated to the retail banking business line? On the other hand, if the said activity is carried out by the entity in a separate organisational unit with its internal management accounting statements (not necessarily a different legal entity), should its relevant indicator (calculated from the management P/L account) be mapped into the business line established by Article 317 CRR (as an example, in the case of placement of financial products, to retail brokerage)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4433
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Passporting and eIDAS certificates

Do account servicing payment service providers (ASPSPs) have to check that third party providers (TPPs) are authorised to operate in their Member State via freedom to deliver services passporting? If so, how shall this be done?

  • 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: 2018_4432
  • Topic: Passporting
  • Date of submission:
  • Published as final Q&A: 26/04/2019

Treatment of joint credit obligations

Do the requirements established in the Guidelines on the application of the definition of default under Article 178 of Regulation (EU) No 575/2013 regarding joint credit obligations, and in particular the requirements 95, 96, 97, 98, 99, 103, 104 and 105, relate or affect exclusively to retail exposures? In that case, could the treatment of joint credit obligations in which the obligors are classified as Non – Retail differ from the treatment of joint credit obligations in which the obligors are classified as Retail? In addition, and, as per this purpose, what should be the treatment of joint credit obligations shared by retail and non-retail obligors?

  • 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: 2018_4431
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/08/2020

Application of the Low Value Transaction Limits

Should the limits according the Article 16 RTS be applied to the account itself (account holder and authorized persons together) or should they be applied to the account holder (owner) and each authorized person (i.e. proxy of account holder) separately? Subsequently should the limits be applied to all remote payment transactions together or should e.g. card transactions and credit transfers be counted separately. Also should the limit be applied to all cards belonging to one person together or should the limit be applied to each card separately?

  • 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: 2018_4429
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/04/2019

EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)

What is the correct interpretation of instrument No.40?

  • 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: 2018_4428
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Supervisory Benchmarking Exercise 2019: RWA- and RWA --

For the purpose of Template C103 institutions shall report RWA- and RWA--. According to the corresponding instructions (Annex IV), RWA- and RWA-- result from the application of PD- and PD-- (instead of the institution’s PD values). For this purpose, shall regulatory PD-floors as defined in art. 160 (1) and 163 (1) CRR be applied?

  • 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: 2018_4427
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Treatment of originated credit-impaired financial assets

Is it possible to apply the rules valid for purchased assets defined in Article 166(1) CRR for originated credit-impaired financial assets as well?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4426
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Scope of "Written Credit Derivatives"

Under Article 429a(5) of the Regulation (EU) No 575/2013 (CRR), as modified by Commission Delegated Regulation (EU) 2015/62, for written credit derivatives, institutions shall include in the exposure value the effective notional amounts, in addition to the treatment laid down in paragraph 1. Is it allowable to exclude from the scope of written credit derivatives, OTC derivatives on high credit quality central government bonds?

  • 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: 2018_4423
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 26/02/2021

Reclassification of own funds instruments from a grandfathered category to a fully eligible category and purpose of grandfathering provisions

Is it permissible for an institution, and if so under which circumstances and/or criteria, to reclassify own funds instruments from a grandfathered category to a fully eligible category in particular in a context where no change in the relevant applicable laws or terms and conditions of the reclassified instruments has taken place before the reclassification? Would the answer be the same for a reclassification of own funds instruments from a disqualified category to a fully eligible category?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4417
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 21/12/2018

Own funds

Article 63 j) of CRR states that "the instruments or subordinated loans, as applicable, may be called, redeemed or repurchased or repaid early only where the conditions laid down in Article 77 are met, and not before five years after the date of issuance or raising, as applicable, except where the conditions laid down in Article 78(4) are met". If an institution has a right of early redemption (not connected to the conditions laid down in Article 78(4)) which is effective five years after issuance but which has to be notified at least two years before redemption, is the instrument eligible as Tier 2 Capital ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4416
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Dynamic linking for batch transactions

In relation to payment transactions for a batch of remote electronic payments to one or several payees, please clarify whether the payer needs to be made aware of every payee in the batch?

  • 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: 2018_4415
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Usage of SMS for dynamic linking

Please clarify whether payment information and an authentication code sent via SMS to a mobile phone complies with the requirements for Dynamic Linking as defined in Article 5 of the RTS, and in particular paragraph 5.2.

  • 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: 2018_4414
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/02/2021

Qualified certificate under eIDAS for ASPSP

Is it required for an Account Servicing Payment Service Provider (ASPSP) to use qualified certificates under eIDAS to identify itself to a Third Party Provider (TPP)?

  • 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: 2018_4413
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/06/2019

Counterparty of deposits taken from a fiduciary bank

Do fiduciary deposits that are taken from a fiduciary bank for risk and reward of an underlying retail client qualify as retail deposits as defined in article 3 of the Delegated Regulation 2015/61?

  • 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: 2018_4412
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Maturity of instruments subject to a cash flow schedule

Should an institution that has received the permission of the competent authority to use own LGDs for exposures to corporates, apply the formula in Article 162(2)(a) CRR, for both fixed interest rate and variable interest rate loans, where no change of the cash flow timing is applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4410
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/05/2021

Securitisations reporting in C 09.04 for v 2.8

How should the securitisations under the new framework be reported in template C 09.04 in v 2.8?

  • 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_4408
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Fair value adjustments that arise as a result of applying fair value hedge accounting

Should fair value adjustments which arise as a result of applying fair value hedge accounting to mitigate interest rate risk be treated under the CRR credit risk framework or under a different risk framework? And if under a different risk framework, which risk framework should that be?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4406
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Subsequent instances of a recurring card payment transaction, other than the first, initial one, are transactions initiated by the payee only. This is also the case for card instalment transactions.

Are the subsequent instance of card payment recurring transactions (other than the first, initial one) and of instalment transactions (again, subsequent to the initial one) transactions initiated by the payee only?

  • 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: 2018_4404
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019