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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

Reporting of Negative Fair Value Hedge Adjustments as exposures

How should the fair value hedge adjustment amounts be reported in template C 08.01 in Annex I of Regulation (EU) 2021/451? Is it acceptable to report the exposures on row 0170 ‘Exposures from free deliveries applying risk weights under the alternative treatment or 100% and other exposures subject to risk weights’? Consistently, should EBA validation rules v0330_m, v0333_m, v0334_m, v10312_s and v10485_s be amended in a way not to trigger validation errors in cases where the fair value hedge adjustment amounts get negative values?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6575
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

Encumbrance of assets

If the reporting institution has a HQLA pledged as collateral for a punctual transaction without any additional liquidity movement (no cash leg) for two days on the reporting date, should this asset be considered buffer as it will be unencumbered within the following 30 calendar days even if in the reporting date it is encumbered? should it be reported as inflow for two days and then as buffer? 

  • 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: 2022_6574
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 21/12/2022

Confirmation of compliance with Article 429b(3c) concerning the interest calculation in Notional Cash Pooling

Can a Notional Cash Pooling which charges or pays interest by using an algorithm which takes into consideration each single current account belonging to the Notional Cash Pooling structure, be considered compliant with art.429b. paragraph 3c of CRR2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6573
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 14/04/2023

SA-CCR cap margin agreement

How do you calculate the cap for netting sets subject to a contractual margin agreement mentioned in Article 274(3) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6571
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/11/2022

Initial Capital

What is the initial capital requirement if a payment institution is providing: (a) any of the payment services as referred to in points (1) to (5) of Annex I and service (6) and (7). (b) any of the payment services as referred to in points (1) to (5) of Annex I and service (6) . (c) any of the payment services as referred to in points (1) to (5) of Annex I and service (7).

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6570
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as Rejected Q&A: 10/07/2023

Validation rule v7371_m

The formula of EBA validation rule v7371 _m is the following: [C 14.01 (All rows)] xsum({C 14.01, (c0310, c0320, c0330, sNNN)}) <= {C 14.00, c0140}. This rule is activated in DPM 3.0 for templates C 14.00 and C 14.01, and states that the total amount of securitized exposures should be equal to or lower than the amount of notes issued in the senior/mezzanine/first loss tranches. However, depending on the characteristics of the securitization structure and the timing of the notes payments date, the amount of securitized exposures can be either higher or lower than the amount of notes issued.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6569
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/01/2023

FINREP - v10612_m in F 18.00

Vorremmo sottoporvi un dubbio in merito alla validation rule v10612_m: La regola verifica che i “di cui” per Stage (per i bonis esposti nel F 18.00 alle colonne c0141, c0142 e c0143) corrispondano alla colonna di totale c0140. Il controllo viene effettuato anche sulla riga 0480 che, al suo interno, contiene gli accantonamenti per “Altri impegni dati“ valutati ai sensi dello IAS37 IFRS4 (referenziati nel template F 09.1.1 in colonna 0110) non ripartibili per stage. Il totale bonis e non performing presente in colonna 0130 dell’F 18.00 è invece confrontabile con il totale presente nella Riga 0170 dell’F 09.1.1). Translation We would like to ask a question about the validation rule v10612_m. The rule checks that the ‘Of which’ per stage (for performing exposures shown in F 18.00 in columns c0141, c0142 and c0143) correspond to the total column c0140. The check is also carried out on row 0480, which contains the provisions for ‘Other Commitments given’ assessed under IAS 37 IFRS 4 (referenced in template F 09.1.1 in column 0110) which cannot be broken down by stage. On the other hand, the total performing and non-performing exposures in column 0130 of F 18.00 can be compared with the total in row 0170 of F 09.1.1).  

  • 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: 2022_6568
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2023

Own-conversion factor estimation for fully-drawn facilities

Are observed defaults of credit facilities that are fully-drawn at reference date in scope for estimation of own-conversion factors?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6567
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 23/02/2023

Recognition of plots of land as real estate collateral

There are plots of land that are owned by individuals or businesses that have been purchased for future use without (e.g. dowry, future residential building for own use, commercial exploitation, etc) but without any current indication of what its use will be. It is a form of investment without any current indication of its exploitation. These plots of land are usually in the form of additional collateral for personal loans or business loans. Can these be recognised as commercial real estate collateral under article 126 if all minimum requirements are satisfied?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6566
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/12/2022

Inclusion of repurchase transactions in financial assets and exposure value/risk-weighted assets (COREP C33).

What is the method to be followed concerning the inclusion of repurchase transactions in financial assets and exposure value/risk-weighted assets in COREP template C 33.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6565
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Clarification on summing columns in Template 10 "Other climate change mitigating actions that are not covered in the EU Taxonomy"

We ask for clarification whether 'columns d' and 'e' in Template 10 (respectively 'Type of risk mitigated (Climate change transition risk) ' and 'Type of risk mitigated (Climate change physical risk) ') should add up to 'column c' ('Gross carrying amount (million EUR) ')?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6564
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

When to apply CCF to residential mortgage off balance sheet exposure

For off balance sheet exposures, when Article 125(2)(d) references 'the part of the loan' that is less than or greater than 80% of the property value, does this refer to exposure, or gross loan balances. Therefore, should the required CCF be applied before or after comparing the balance commitment to the property value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6563
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/11/2022

Applicable remuneration policy

The question relates to members of staff who are classified as identified staff by the group, whose country of employment is a third country, and who are also appointed as non-executive directors (“NEDs”) on the board of directors of a subsidiary credit institution licensed in a Member State (“EU subsidiary”). These NEDs are classified as identified staff for the EU subsidiary but are not seconded to the EU subsidiary and are not paid any form of remuneration or emolument for their directorship on the EU subsidiary. In such case, should the remuneration policy of the EU subsidiary apply to such NEDs even if they do not receive any form of compensation/benefit whatsoever for their role with the EU subsidiary? Whilst in relation to seconded individuals this matter has been clarified in the EBA GLs on sound remuneration policies (EBA/GL/2021/04), it is still not expressly clear whether any such NEDs would also be subject to the EU subsidiary’s remuneration policy. In this case it is reasonably expected that given that such NEDs are not being paid either directly or indirectly for the services they are rendering to the EU subsidiary, the group’s remuneration policy (rather than the EU subsidiary’s remuneration policy) is to apply. It would be appreciated if this point is clarified.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6562
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 07/09/2022

Financial guarantees received reported in F 09.02

Should financial guarantees received be reported in template F 09.02 with their nominal amount (as it is explicitly noted for the financial guarantees given in paragraph 118, Part 2 of Annex V to Regulation (EU) 2021/451 (ITS) or the maximum amount that can be considered is the maximum amount the counterparty would have to pay if the guarantee is called on as of the specific reporting date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6561
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Pillar 3 disclosure on Net Stable Funding Ratio

How should NSFR LIQ2 table for Pillar 3 disclosure be compiled with respect to amounts reported in NSFR regulatory template C80 rows 0040, 0050 and 0060 for the non-HQLA part (i.e., 0010, 0020, 0030, respectively weighted by applicable weights reported in columns 0090, 0100, 0110). Those items seem to be not included in any of the weighted RSF items/components of LIQ2.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6560
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 30/01/2023

Wrong validation at the level of the number of obligors between C08.01 and C34.07.

  May we kindly ask you to disable validation rules v10523_h and v10524_h? These checks are not correct. This item is closely linked to a previous Q&A with the ID 2021_6202, we can however not find this Q&A on the EBA site.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Traditional SRT securitisations with derecognized underlying assets

According to the instructions included in Regulation (EU) 2020/429, the column 0210 of C 14.00 shall show the following: “…Value adjustments shall include any amount recognized in profit or loss for credit losses of financial assets since their initial recognition in the balance sheet.” Additionally, based on Q&A 5077, where an inconsistency in validation rule v4797_m in template C 14.00 is raised, the provisions reported in column 0210 are referred to outstanding nominal amount at the reporting date. How should column 0210 be filled in case of traditional SRT securitisations, where the underlying assets are entirely derecognized and for which no provisions are recognized in balance sheet after the origination?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6558
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 29/06/2023

Treatment of Security Lending and Borrowing Transactions for LCR purposes

How should Security Lending and Security Borrowing Transactions be reported in the LCR template, considering the changes introduced by the Commission Delegated Regulation (EU) 2022/786 about Security Financing Transactions? In detail, shall Security Lending and Borrowing transactions be reported as collateral swaps in C 75.00 template or shall they be reported as Security Financing Transactions in C 73.00 and C 74.00?

  • 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: 2022_6557
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 26/05/2023

COREP C35 - consistency controls v09703_m and v09711_m

The control claims that for C35.01 row r0070 should be the sum of row r0080-r0100 of C35.02 and row r0070 and row r0120 of C35.03. Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6556
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2023