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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.

List of Q&A's

Consideration of collateral in the current exposure method

We seek clarification regarding the consideration of collateral in the current exposure method (referred to as the Mark-to-market method in Regulation (EU) No 575/2013 (CRR) for the own capital requirements as well as for the large exposure regime. Is it possible to allow for collateral posted in calculating the current replacement according to Article 298(1)(c)(i) of Regulation (EU) No 575/2013 (CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

10% limit for significant investments (for threshold exemptions determination purposes)

Could the EBA confirm that in a situation where the total amount of significant investment in a financial sector entity (the direct, indirect and synthetic holdings by the institution of the Common Equity Tier 1 instruments of that entity) exceed 10% of relevant Common Equity Tier1 items, such amount can be included in 15% threshold exemptions up to 10% of this amount and remaining surplus above 10% limit will be treated as a deduction of CET1. Example in background.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

COREP securitisations (crsecirb, crsecsa and crsecdetails)

It is unlcear from the instructions for the COREP which securtisations exposures should be filled in, in which tab (crsecirb, crsecsa and secdetails).

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

IFRS references of column 110 “Accumulated write-offs” of F 07.00 template

What is the meaning of the references to IAS 39 AG 84-92 provisions (related to impairment losses) in the column 110 of F 07.00 template?

  • 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)

Removal from the balance sheet of loans considered uncollectible (write-off in the context of the financial reporting form F 07.00)

Considering the fact that the write-off definition provided by para.49 from Part 2 of Annex V to the ITS (FINREP instructions) seems to depart from the IAS 39 derecognition principles, what did you envisage when requesting the amounts to be reported in the column 110 “Accumulated write-offs”? More specific, could you provide us examples of situations leading to filling in the column 110 “Accumulated write-offs”?

  • 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)

Allocation of the collective impairment allowances

In order to fill in the FINREP templates, how should be performed the allocation of the collective impairment allowances among group assets?

  • 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)

Financial assets impairment

Where should be reported in the financial reporting forms F 04.04 and F 07.00 the allowances related to individually insignificant financial assets which were not assessed for impairment on individual basis (following the option of IAS 39.64), but were found collectively impaired?

  • 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)

Financial assets impairment

Considering the provisions of para.37 from Part 2 of Annex V to the ITS (FINREP instructions), are there any IFRS provisions allowing entities to perform the computation of the impairment losses at the portfolio level for individually insignificant financial assets found to be impaired on individual basis?

  • 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)

Financial assets impairment

Do impaired financial assets also include the ones that are found to be impaired at the group level or only those individually impaired? More specific, in the financial reporting form F 04.04, the column 020 “Impaired assets [gross carrying amount]” includes only the financial assets impaired on individual basis (with specific allowances for individually assessed financial assets or specific allowances for collectively assessed financial assets)?

  • 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)

Level of application of the new FINREP framework

Can a competent authority impose FINREP at a solo level. Moreover, would a competent authority be free to add to or delete information from a specific template?

  • 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)

Scope of application of the new FINREP framework

Are the credit institutions that should not prepare consolidated accounts according to the prudential rules under the scope of the new FINREP framework?

  • 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)

FINREP: F07.00 reporting of past due assets

How to split past due not impaired financial assets according to the number of days past due? According to the Instructions in Part 2, paragraph 48: “Assets qualify as past due when a counterparty has failed to make a payment when contractually due”. Q1: Will the whole asset/loan be qualified as past due or only its part, for which the counterparty failed to make a payment? According to the Instructions in Part 2, paragraph 48 : “The amounts of such assets shall be reported and broken down according to the number of days past due”. Q2: Should the individual financial asset/loan be split into parts according to the “age” of individual instalments or should the financial asset/loan be reported in the col. for the “oldest” past due instalment? In this case “to split” will be relevant to financial assets portfolio (= individual asset will be kept as a whole, but portfolio will be split) .

  • 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)

Correct consideration of the saving accounts in the LCR calculation of outflows following Article 421 (5) of Regulation (EU) No 575/2013 (CRR)

Is it correct that German “Savings Accounts” are to be considered in the LCR calculation only up to the threshold of EUR 2000,- penalty-free withdrawals per account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of the words "on group basis"

What is the definition of the words “on a group basis” in Article 411 (2) of Regulation (EU) No 575/2013 (CRR)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Consideration from residual values in the LCR calculation

As significant inflows from residual values of large portfolios of leased cars are not regulated within Part 6 of Regulation (EU) No 575/2013 (CRR) how may institutions who professionally manage such portfolios take those values into account?

  • 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

Notifications of agents and subagents of credit institutions in the European Economic Area (EEA)

1) Is it allowed for a credit institution to provide money remittance services via agent cross-border in the EEA? 2) Do agents have to be notified to the home-/host authority and if so under which directive? 3) Do agents have to be notified by way of freedom of establishment or by way of freedom to provide services? 4) Are agents to be treated as branches? 5) Is it allowed for an agent of a credit institution which provides money remittance services cross-border in the EEA to use subagents? If yes: a) Does a sub-agent have to be notified? b) On which legal basis? c) To which Authority? d) Does the credit institution or the agent provide notification and, if so, freedom of establishment or by way of freedom to provide services?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Outflows associated with shorts - net or gross

Can you clarify whether Article 423(4) of Regulation (EU) No 575/2013 (CRR) requires firms to: 1) assess long and short positions gross per ISIN and to treat shorts gross by ISIN, reporting an outflow under Article 423(4) corresponding to the sum of all the gross short positions per ISIN (not covered >30 days); or 2) assess shorts net of any longs currently used to cover shorts via stock collateralised stock borrow e.g. a long in one ISIN (not qualifying as liquid assets per Article 416) that is currently used as collateral to cover a short in another ISIN (stock collateralised stock borrowing) and maturing inside 30 days, can continue to be eligible as collateral to cover shorts thus reducing the outflow reported under Article 423 (4).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Leverage Ratio: C45.00 (LRCalc) r010: SFTs exposure according to CRR 220

The exposure for repurchase transactions, securities or commodities lending or borrowing transactions, long settlement transactions and margin lending transactions should be calculated in accordance with Article 220 (1) to (3). Should the volatility adjustments be taken into account for the determination of the leverage ratio exposure value of exposures subject to Article 220?

  • 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)

Firm shorts covered by client longs

We assume that an outflow should be reflected under Article 423 (4) of Regulation (EU) No 575/2013 (CRR) for any firm short currently covered using a client long position, unless the residual term of the borrowing of the client stock used to cover the short is contractually committed beyond 30 days.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

FINREP: Counterparty breakdown - hospitals, schools, social secretaries

As what counterparty shall hospitals, schools and social secretaries be reported? Are there any thresholds (e.g. turnover) which when exceeded then the entity shall be reported as different counterparty (e.g. in current FINREP hospitals are treated households, when turnover exceed the limit then the hospital is reported as corporate)?

  • 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)