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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

Look-through approach resulting in a credit risk position of own institution

When applying the look-through approach of Article 132(4) CRR, what risk weight shall an institution apply to a position that is based against its own institution?

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

New risk weights for exposures to central governments or central banks not applicable in DPM 2.7 for C 07.00

How should the new risk weights be applied when they are not currently available in the DPM 2.7?

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or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Report gross or netted cash flows in the row 360 of C66 (maturity ladder) of non-forex and non-option-like derivatives under a valid netting agreement but without collateral agreement

« In the Annex XXIII (Maturity Ladder Instructions), for the row 360 ("1.5 Derivatives amount payables other than those reported in 1.4") , paragraph 2(b), it is stated that "flows related to other contracts than those referred to in point (a) shall be included by projecting the gross contractual flows of cash in the respective time buckets in lines 1.5 ‘derivatives cash- outflows’ and 2.4 ‘derivatives cash-inflows...’". Suppose that there is a group of derivatives (non-forex, non-option-like transactions) traded with the same counterparty under a valid bilateral netting agreement but without a collateral agreement in place, should netted cash flows per counterparty or gross cash flows be reported in row 360? If the netted cash flows should be reported in row 360, should the netted amount be calculated per day, or per time bucket defined for C66 report? For example, in C66, there is a time bucket 'Greater than 7 days up to 2 weeks', can we net an inflow of day 8 with an outflow of day 9 and then report only the net amount in row 360 (if negative) or row 670 (if positive)?”

  • 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)

Pillar III templates aligned with the new supervisory reporting package, DPM 2.7

Should we adjust template EU CR2-A in order to facilitate the implementation of the EBA Guidelines on disclosure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Meaning of current year in validation rule v6167_m

What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

  • 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)

Article 473a(2) – Consideration of accounting provisions for FVOCI debt instruments

Should the ECL on debt instruments classified at fair value through OCI under IFRS9 be included within the calculation of the amount to be added back to CET1 as set in Article 473a.2 ( “static approach”)?

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

Interaction between Articles 473a and 127 of the CRR (risk weight factor for exposures in default under the standardised approach)

Do banks in order to calculate the thresholds of Article 127 of Regulation (EU) No 575/2013 (CRR) have to consider all IFRS 9 provisions (without applying any scaling factor) or the amount of IFRS 9 provisions reduced by applying the scaling factor as per Article 473a?

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

IFRS 9, validation rules v6012_m, v6013_m and v6014_m

In template F18.00 rows 211 to 231 for columns 120 and 140 and in template F19.00 rows 211 to 231 for columns 100 and 130 need to be opened. Validation rules v6012_m, v6013_m and v6014_m need to be deactivated as long as these positions are greyed out. These VRs may not be applicable for reporters under nGAAP that measure debt instruments at strict LOCOM and recognize accumulated impairment for performing exposures. Furthermore debt instruments measured at strict LOCOM under Austrian nGAAP are recognized as impaired assets in case there are negative credit-risk induced value adjustments.

  • 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)

Goodwill included in the valuation of significant investments

1. For the purposes of Article 37(b) CRR, are the significant investments of the institution limited to the significant investments in financial sector entities (FSE) or should they include all significant investments (i.e. also significant investments in entities that are not financial sector entities)? 2. Should Article 37(b) CRR be applied only when the significant investments outside the prudential perimeter are valued for prudential purposes using the equity method or should it be applied also when the significant investments are valued for prudential purposes at historical cost? 3. Should the amount to be deducted pursuant to Article 37(b) CRR be limited to goodwill or should it include also the other intangible assets included in the valuation of the significant investments of the institution?

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

Requirements in Commission Delegated Regulation (EU) 2016/1712

- Do the requirements in Commission Delegated Regulation (EU) 2016/1712 only apply to financial contracts resulting in a liability which could be subject to bail-in under resolution, rather than all assets and liabilities?- Are there any expectations on the format/method of submission for the information if/when requested (i.e. excel, CSV, other)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

IFRS 9 Transitional arrangements - Calculation of the amount of CET add-back in accordance to Article 473a – paragraph 4

How should the amount referred to in Article 473a(4) be calculated:a) The difference between the Expected Credit Losses (ECL) at reporting date for loans that are not credit impaired and the ECL at implementation date for all the loans that are not credit impaired at the implementation date, or;b) The ECL at reporting date for loans that are not credit impaired minus the ECL at implementation date for those same loans?

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

IFRS 9 Transitional arrangements – Reporting of impact on Standardised exposure value of transitional credit risk adjustments

According to Article 473a(7)(b) of CRR, is it possible to report the impact on Standardised exposure value of transitional credit risk adjustments in COREP at an overall level?

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

IFRS 9 Transitional arrangements - Calculation of the amount available for CET1 add-back

When assets were measured at amortised cost in accordance with IAS 39 then classified as FVTPL under IFRS 9, should they be included in the calculation of the ‘day 1’ static amount to be added back to CET1 as set in Article 473a(2)(b)?

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

Classification of a commitment to make under certain conditions an indemnity payment for a customer

Does a commitment to make under certain conditions an indemnity payment on behalf of a customer constitute an “off-balance sheet item other than those mentioned in (Article 166) paragraphs 1 to 8” according to Article 166(10) CRR?If so, does it constitute a medium/ low risk item according to Article 166(10)(c) CRR, specifically as one of the “other items also carrying medium/low risk and as communicated to EBA” according to Annex I, No. 3(b)(ii) CRR?

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

Treatment of off-balance sheet exposures measured at reporting date at fair value trough P&L in templates F 18.00 and F 19.00

How should we treat off-balance sheet exposures measured at reporting date at fair value trough P&L from the reporting templates F 18.00 and F 19.00 point of view? Shall we include them into templates or not?

  • 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)

Gross carrying amount for purchased credit-impaired assets in FINREP and COREP

How should we define gross carrying amount of purchased credit-impaired assets (POCI) for reporting into FINREP templates (i. e. F 18.00 and F 19.00)? Related to gross carrying amount in previous question, how should we in define original exposures for reporting into COREP and LE templates? How should we calculate coverage ratio by allowances or provisioning for credit losses, if the value of allowances for expected credit losses related to the POCI is positive? For example: In Q1 2018 bank A simultaneously with other forbearance measures in respected existing exposures to the debtor who is already in default, grants him a new loan in CU 100.000 (=so-called transaction price). There is evidence that the loan is already credit-impaired at initial recognition, based on that fact bank identified this exposure as an originated credit-impaired financial asset in stage 3 (=POCI).The fair value of the loan at the time of drawdown (i.e. at initial recognition) is only CU 55.000, mainly due to the significant credit risk value adjustment. Therefore, bank at initial recognition in accordance with paragraph B5.1.2A (b) of IFRS 9 recognises one-day profit or loss (P&L) in CU 45.000. Bank recognises also allowance for expected credit losses (ECL) in CU 1.000. In Q4 2018 bank find out that estimated allowance for ECL in CU 1.000 and negative fair value adjustment due to credit risk in CU 45.000, which was, taking in to account one-day P&L and calculation of credit-adjusted effective interest rate under paragraph 5.4.1 (a) of IFRS 9, too pessimistic. Therefore, bank reverses allowances from the previous period in CU 1.000. In addition, bank recognises positive amount of allowances for ECL in CU 2.000. The same situation could happened if Bank A modified financial assets, which in accordance with paragraph B5.5.25 of IFRS 9 would result in the derecognition of the existing financial asset and the subsequent recognition of the new modified financial asset. If there is evidence that the new modified financial asset is credit-impaired at initial recognition, it should be in accordance with paragraph B5.5.26 of IFRS 9 recognised as an originated credit-impaired financial asset (=POCI). Based on presented example, which option to calculate the gross carrying amount under paragraph 34 (b) of Part 2 Annex V of Regulation (EU) No 680/2014 for reporting purposes in the FINREP templates is correct: Option A: Fair value of financial asset defined at initial recognition in accordance with paragraphs 5.1.1, 5.1.1A and B5.1.2A of IFRS 9, as the starting point for using amortized cost method at subsequent measurement, because FINREP templates in general follow IFRS. According end of the Q1 and Q4 gross carrying amount is CU 55.000 (= transaction price in CU 100.000 minus recognised one day P&L in CU 45.000). Option B: Fair value of financial asset after adding back any negative fair value adjustment due to credit risk at initial recognition of financial asset, as starting point for credit losses calculation both for accounting and for capital adequacy purposes. According end of the Q1 and Q4 gross carrying amount is CU 100.000 (= transaction price). In this case negative fair value adjustment due to credit risk at initial recognition in CU 45.000 should increase amount of allowances for ECL. How should we, in respect of gross carrying amount in the example, define original exposures for the purpose of including in COREP and LE templates, in accordance with option A or option B?

  • 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)

Validation rules v5434_m to v5447_m in DPM 2.7.0

Are validation rules v5434_m to v5447_m correct?

  • 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)

Validation rule v2818

Is there is an error in validation rule V2818 (check between AE and FINREP CON)? It caused a blocking error on the side of our institution. ERROR : v2818_m: sum({F 32.01, r070, (c010, c060)}) = {F 04.01, r080,c010} + {F 04.02.1, r070,c010} + {F 04.02.2, r080,c010} + {F 04.03.1, r070,c010} + {F 04.04.1, r030, c010} + {F 04.06, r080, c010} + {F 04.07, r080, c010} + {F 04.08, r080, c010} + {F 04.09, r030, c050} + {F 04.10, r080, c010} : [F 32.01: 22693164316; FINREP: 734022053; 596916000; 0; 11242205575; 10104104910] It checks debt securities issued by central banks and general governments. Apparently in the control some FINREP cells for central banks are missing. For example: {F 04.01, r070,c010} {F 04.03.1, r060,c010} {F 04.04.1, r020, c010} I see no reason why these fields are missing in the rule.

  • 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)