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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 to the wording “joint decisions should be taken by national authorities concerned” in Recital 98

Could you clarify what is meant by the wording “joint decisions should be taken by national authorities concerned” in Recital 98, and in particular what is meant by the provision “joint decision shall be recognised as conclusive and applied by the other resolution authorities concerned”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2070
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Clarification to Recital 41

Do you agree that the word “not” is missing in Recital 41 and should be corrected? (“Resolution should be initiated when a competent authority, after consulting a resolution authority, determines that an institution is failing or likely to fail and alternative measures as specified in this Directive would not prevent such failure within a reasonable timeframe.”)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2069
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 24/07/2015

Determination of the exposure at defaul in case of unfunded credit protection

Under the advanced approach, the IRB Approach, as permitted by the Title II - Chapter 3, does not specify the order of application of the Credit Conversion Factor (CCF) and of the credit protection when an off-balance sheet exposure is covered by an unfunded credit protection (e.g. a CDS, Credit Default Swap). Does CRR prevent from applying the credit protection on the Exposure At Default (i.e.: after application of the CCF for an off-balance sheet exposure)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2063
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/06/2016

Scope of funding applicable

For template 69, prices of various lengths of funding, should own funds i.e. tier 1&2 be considered as funding and therefore applicable to be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_2061
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

F 33.00 - MATURITY DATA (AE-MAT) - Maturity of the encumbered asset

How to report initial margin (IM) and variable margin (VM) under F33 Maturity data report - 010-encumbered assets? Given there is no clear guidance on this particular maturity reporting therefore it is grateful if EBA could provide a clearer guidance or best practice on this issue.

  • 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: 2015_2060
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/06/2021

Number of distinct calculations required to assess materiality of changes to internal IRC models

Regulation (EU) No 529/2014 governs the assessment of materiality of changes and extensions to internal approaches for credit, market and operational risk. According to this regulation a change to the incremental default and migration risk charge (IRC) is to be considered material if within 15 consecutive business days (Article 7a(4)(a)) the thresholds of Article 7a(1)(c)(ii) are breached at least once. According to Article 374(1) CRR institutions may compute the IRC only weekly. Does this mean that?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2015_2058
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 25/09/2015

FINREP Template 19 - column 050 - of which: Performing forborne exposures under probation

Due to the amended wording, it is unclear, whether only performing forborne exposures under probation which have been reclassified out of the non-performing forborne exposures category shall be reported in column 050 or all performing forborne exposures under probation which have been reclassified out of non-performing category at any time in the past. Regarding the two examples given below, the question is if both exposures have to be reported in column 050 of template F 19.00 or only exposure A? Exposure A was classified as non-performing with forbearance measure and fulfilled all required exit criteria mentioned in paragraph 157. Thus, exposure A was reclassified out of the non-performing forborne exposures category and has to be reported in column 050 as long as it does not fulfil the exit criteria of paragraph 176. Exposure B was classified as non-performing 2 years ago, no forbearance measure was granted. One year ago, exposure B fulfilled all exit criteria of paragraph 156 and was reclassified as performing. Six month ago, on exposure B an forbearance measure was applied which has not led the exposure to be classified as non-performing. Does exposure B have to be reported in column 050 of template F 19.00 due to the fact it was reclassified out of the non-performing category (without forbearance measure) one year ago?

  • 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: 2015_2056
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Client servicing in the definition of the trading book

According to Article 4(1)(85) and (86) of Regulation (EU) No 575/2013 CRR, are all proprietary positions and all positions arising from client servicing and market making trading book positions, irrespective if they are held for short term or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2054
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 01/04/2022

Reportable maturity for ALMM C69 PRICES FOR VARIOUS LENGTHS OF FUNDING

In what time bucket in template 69 shall deposits without stated maturity be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_2051
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Reporting requirement for draw down of facilities

In the case of revolving committed credit facilities, should the capacity of facility, upon renewal/commencement of the arrangement, or each individual draw of the facility be reported for the volume amount in template 69?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_2049
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Funding plans projection horizon for the June 2015 reference date

Can you please clarify whether the projection horizon for the June 2015 reference date relates to (a) Dec 2015, June 2016, June 2017 and June 2018 for each of columns 020 to 050 respectively, or (b)Dec 2015, Dec 2015, Dec 2016 and Dec 2017 for each of columns 020 to 050 respectively

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2015_2048
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Validation rule v4421_s does not comply with validation rules v4117_m, v4118_m, v4119_m, v4120_m as it implies a negative sign for maturing long term funding

Validation rule v4421_s implies that maturing long term funding must be reported with a negative sign for different categories of long term funding in row (200,230, 260,290,320) and column (020,030,040,050) in template P 01.02. However, this contradicts with validation rules v4117_m, v4118_m, v4119_m and v4120_m.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2015_2046
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Market making in several AT1 or T2 instruments

Where an institution applies for a prior permission for repurchase of several Additional Tier 1 or Tier 2 capital instruments according to Article 78(1), second subparagraph, of the CRR, may the predetermined amount of the permission be set for several instruments or must a predetermined amount be set for each instrument?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2015_2042
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 25/09/2015

Level 1 assets and Large Exposures exemptions

Please can you confirm that debt securities with a 0% risk weight under Part Three, Title II, Chapter 2 that are reported as level 1 assets in accordance with Article 10 point 1(e)(ii) of the Delegated Act specifying the LCR should also be exempted from the Large Exposure Limits defined in Article 395(1) of Regulation (EU) No 575/2013 under the exemptions in Article 400 point 2(d)(e)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2040
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 27/05/2016

FINREP – Reporting of accumulated changes in fair value due to credit risk and FINREP sign convention

What is the DPM sign convention for templates where accumulated impairment and accumulated changes in fair value due to credit risk are reported? Are all validation rules applicable?

  • 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: 2015_2034
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 26/06/2015

Concentration of funding by counterparty (C 67.00) ranking

C 67.00 (Concentration of funding by counterparty): Shall we compute/report the top 10 counterparties for each currency, or is the currency irrelevant to compute this rank?If the currency is irrelevant, the top 10 counterparties would be the same list across all significant currencies sheets, with some empty results/rows for counterparties not concerned by all significant currencies.C 68.00 (concentration of funding by product): The regulation clearly states that the currency is irrelevant for product types determination above the 1% threshold (Annex 4 XIX, chapter 1.3, paragraph 4). Does this mean also that the list of products concerned is the same list across all significant currencies sheets?C 67.00 / C 68.00: If we want to keep consistency between reports C 67.00 and C 68.00, shall we apply the same principle: currency is irrelevant for ranking or sorting?

  • 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: 2015_2033
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Will the application of the cap on inflows be applicable at the single material currency level

Should the inflow cap, limiting inflows to 75% of liquidity outflows, apart from specifically outlined exemptions, be applied in relation to single material currency LCR reporting or just at the all currency combined LCR calculation?

  • 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: 2015_2031
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 01/04/2016

For trade finance transactions within 30 days to maturity the DA indicated a 100% inflow for financial customers, however we understand this was for all customers

Regulation (EU) No 575/2013 article 425 2 (b) indicates that monies due from trade finance transactions within 30 days are a taken account in full. However the Delegated Regulation (EU) 2015/61, article 32 2 (a) and its associated sub paragraph (ii) read as if this only relates to financial customers, therefore are trade finance trascations from non-financial customers less than 30 days to maturity to be taken into account in full as inflows?

  • 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: 2015_2030
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022