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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

Inconsistency between the report DPM table layout and data point categorization 4.2 and EBA Annex II Instructions.

'- In the DPM 4,2 file in tab Z_07.01.3 a and c, the fields 0100 (Number of transactions) and 0110 (Number of clients) are the components of the Cross Border Activities section. In the Annex II Instructions, the fields 0100 and 0110 are not subject to the Cross Border Activities section but they concern the number of clients and transactions of the total economic function. - In the DPM 4,2 file in tab Z_07.01.4, the fields 0090 (Number of counterparties) and 0100 (Number of transactions) are the components of the Cross Border Values section. In the Annex II Instructions, the fields 0100 and 0110 are not subject to the Cross Border Values section but they concern the total numbers of the total economic function.  Could you please confirm that the breakdowns in the tabs: Z_07.01.3a for the column 0100, Z_07.01.3c for the column 0110, Z_07.01.4  for the columns 0090 and 0100 are not included in the Cross Border section? 

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

Clarification on the application of Article 215.2(b) of the CRR

Can guarantees issued by a central government for residential mortgages, that covers losses resulting from the non-payment of interest and other types of payments which the borrower is obliged to make, be used for unfunded credit protection if the final guarantee value is determined based on the residual value between an executive sale of underlying residential mortgage collateral and a max guaranteed amount?

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

reverse solicitation

The reverse solicitation is where a client or counterparty approaches an undertaking established in a third country at its own exclusive initiative for the provision of banking services, including their continuation, or banking services closely related to those originally solicited.  Is the invitation letter from the agent bank who arranges for the syndicated loans or Schuldscheindarlehen ("SSD") a sufficient supporting document to evidence that a client approaches us at its own exclusive initiative? Or an independent declaration directly made from the borrower (the client) is required?  

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

Counterparty treatment of Debt Management Offices (DMOs)

How should Debt Management Offices (DMO) be treated in liquidity reporting for counterparty classification purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Applying the provisions of Article 390 (7) CRR and Delegated Regulation 1187/2014 for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets for received collaterals (indirect exposures) after applying substitution approach according to Article 403 CRR 

Does a credit institution have to apply the provisions of Article 390 (7) CRR in combination with Delegated Regulation 1187/2014 to a securitization or investment fund exposure, when the credit institution received the securitization or investment fund exposure as a collateral in an SFT?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

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

FINREP Validation rules v23845_h, v23846_h, v23847_h

Could the EBA clarify the rationale for excluding rows 0015, 0185, and 0365 from the new validation rules for template F 12.01.a?This change creates inconsistencies with cross-template validation rules such as: v6030_m: {tF_12.01.a, r0010, c0100} - {tF_12.01.a, r0015, c0100} = {tF_04.03.1, r0180, c0050} + {tF_04.04.1, r0140, c0050} v6033_m: {tF_12.01.a, r0180, c0100} - {tF_12.01.a, r0185, c0100} = {tF_04.03.1, r0180, c0060} + {tF_04.04.1, r0140, c0060} v6036_m: {tF_12.01.a, r0360, c0100} - {tF_12.01.a, r0365, c0100} = {tF_04.03.1, r0180, c0070} + {tF_04.04.1, r0140, c0070} These rules assume that rows 0010, 0180, and 0360 include “Cash balances at central banks and other demand deposits.” Additionally, the items “of which: collectively measured allowances” and “of which: individually measured allowances” will no longer consider these balances because the related rules (v5054_m, v5055_m, v5056_m) reference rows 0010, 0180, and 0360 only. Could the EBA confirm whether this exclusion is intentional and, if so, provide guidance on how to reconcile these templates and validation rules?

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

Controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m

Please note that controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m should have the condition "eba_qAS:qx2004" instead of "eba_AS:x2" to comply with column 010 of row 010 of report F_00.01

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

C_07.00 : columns 010 to 040 of line 210

I would like to point out that columns 010 to 040 of line 210 of report C_07.00 should have been ungreased in the EBA 4.2 taxonomy to be in accordance with the EBA's answer to question 2025_7348.

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

incoherent formulae

Should the v903188_s control formula apply to columns 0010 and 0020?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

incoherent formulae

Should the v903188_s control apply for establishments that do not supply the C16.04 status?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

incoherent formulae

Is the v90304_m control formula consistent with the other controls on C16.02 ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Foreign Exchange Vega Risk Factors Definition

Shall the foreign exchange vega risk factors to be applied by institutions to instruments in the CVA portfolio sensitive to foreign exchange volatility be the implied volatilities of foreign exchange rates between the contractual currency pairs (i.e., no triangulation with respect to the institution’s reporting currency is required)?

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

Calculation of the unmargined exposure value for a netting set with multiple margin agreement or including both transaction subject to a margin agreement and transaction not subject to a margin agreement

How to calculate the capped exposure value, i.e., the exposure value of the netting set in the event that it is not subject to any type of margin agreement, when there are multiple margin agreements applicable to this netting set or when this netting set includes both transactions subject to a margin agreement and transactions not subject to a margin agreement? For the calculation of the unmargined value, should all deals be included in a single sub-netting set (the one containing contracts not subject to margining) and not divided as required by paragraph 4 of Article 274, or should the sub-netting sets remain separate and their value be calculated as if they were unmargined?

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

Template C90.00 and C90.05

For the purpose of determining the "On- and off-balance sheet business subject to market risk" for template C90, is the netting between long and short positions in the same exact instrument allowed? 

  • 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 (repealed)

Obligations of ASPSPs to inform PISPs about the execution status of individual payments executed under a standing order initiated via API.

Under PSD2, when a PISP initiates a standing order on behalf of a PSU, the ASPSP generally communicates only the result of the standing order setup (i.e. whether the standing order has been accepted or rejected). In practice, PISPs typically do not receive information on the execution status of each individual payment transaction carried out under that standing order, even though each execution constitutes a separate payment transaction under PSD2. This creates uncertainty as to whether ASPSPs are required to make this information available to PISPs in the same way it is made available to PSUs in online banking channels.   Should ASPSPs provide PISPs with information on the execution status (e.g. executed or rejected) of each individual payment transaction executed under a standing order initiated by a PISP?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

COREP C14.00, columns 0140-0225, validation rules v11650_m, v11651_m and v7347_m

Pursuant to para (a) of the definition of originator, the submitter qualifies as the sole originator as an entity which itself or through related entities, directly or indirectly, was involved in the original agreements which created the obligations of the debtors giving rise to the exposures being securitized.  The securitized exposures/obligations were not on the submitter’s balance sheet.  However, given the definition of originator (in particular para (a)) we understand that the presence of the securitized exposures/obligations on an entity’s balance sheet, is not a condition for such entity to qualify as an originator (including as the sole originator). We further understand that in the templates C14.00, the section securitized exposures, columns 0140-0225: apply to an originator of securitization positions which were securitized from such originator’s own balance sheet (‘own portfolio’); do not apply to an originator where the securitization positions were not on such originator’s own balance sheet. If our understanding is correct, please confirm that the submitter, as a sole originator which did not have the securitized exposures/obligations on its balance sheet, should not be required to populate section Securitised Exposures, columns 0140-0225?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Deduction of participations and Corep reporting

For the deduction under article 17 (1)(e), of RTS 241/2014, what is the correct COREP row for reporting this item? Is reporting under row 0529 “CET1 capital elements or deductions – other” appropriate? 

  • 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

Definition of Subordinated Debt holdings in Finrep vs COREP under CRR3

Could you please confirm whether, following the implementation of Regulation (EU) 2024/1623 of the European Parliament and of the Council amending Regulation (EU) No 575/2013 (Capital Requirements Regulation 3 – CRR3), institutions will be required to report subordinated debt holdings differently in FINREP and COREP.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

EBA publication of loss rates for Swiss residential and commercial property under CRR Articles 125 and 126.

Will the EBA publish loss rate data for Swiss residential and commercial property markets to enable institutions to apply preferential risk weights under Articles 125 and 126 CRR? If yes, what is the expected timeline?

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