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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

Definition of "institution" for large exposure purposes

Should EC implementing decision on the equivalence of the supervisory and regulatory requirements of certain third countries and territories for the purposes of the treatment of exposures according to Regulation (EC) No. 575/2013 be used to determine equivalence for LE purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1692
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 15/07/2016

Own funds - underwriting of own funds instruments

Is the underwriting of a Tier 2 (T2) instrument by an insurance subsidiary of the issuer possible when the instrument is then replaced in units of account within life insurance policies where the client bears the economic risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1687
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 01/04/2016

Usage of the internal model for determining the own funds requirements for the specific risk associated with traded debt positions in the advanced method for Credit Valuation Adjustment (CVA) risk

Are divergent internal models allowed for determining the own funds requirements for the specific risk associated with traded debt positions and for the credit valuation adjustment risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 526/2014 - RTS on proxy spread and limited smaller portfolios for CVA risk
  • ID: 2014_1686
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 05/06/2015

Definition of the exposure portfolio for which permanent partial use of standardised approach can be applied for by a credit institution using the IRB approach

Can an IRB credit institution have the standardised approach applied to type of clients to whom the IRB approach is being used? I.e. if the standardised approach is approved for a specific portfolio of exposures, can this portfolio be defined by the type of client only or may it also be defined by the type of business?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1678
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/04/2015

FINREP, template F 20.04

If a bank does business with a branch abroad, how does bank report information regarding Geographical breakdown by residence of the counterparty in table F 20.04 – taking into account the country of branches' residence or the country of mothers' residence? For example, Slovenian Bank A does business with Branch B in Italy, which is the part of Bank C in Slovenia. Should the Bank A report in template F 20.04 their exposure to Branch B of Bank C as an exposure to Slovenia (residence of mother) or as an exposure to Italy (residence of branch)?

  • 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: 2014_1677
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Inconsistent validation rules of asset encumbrance templates (F 32.01, F 32.04, F 36.01)

There are several validation rules that do not appear to be appropriate:v2823_msum({F 32.01, r120, (c010, c060)}) = sum({F 01.01, c010, (r020, r060, r092, r240-260, r290, r320-330, r360-370)})According to the instructions of F 32.01 and validation rule v2814_m, if the asset encumbrance reporting is based on IFRS, then the total assets of the reporting institution (sum({F 32.01,r010,(c010,c060)})) equals to the total assets reported in {F.01.01,r380,c010}.In order to meet this requirement, v2823_m should also contain row280 and row310 of F01.01. Now these items are missing from the formula.Validation rules v2864_m and v2865_m are applicable for rows 020, 030, 050-060 of F 32.04, however row 060 is grey shadowed.In our understanding v3309_i should be applicable only for IFRS banks because {F 36.01, r230, c180} equals to sum({F 32.01, r010,(c010, c060)}) which equals to Total assets of F 01.01 only if the report is based on IFRS. Now the formula doesn’t distinguish between IFRS and non-IFRS banks.

  • 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: 2014_1671
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reporting of cash collaterals included in repurchase agreements in F 08.01

In template F 08.01, repurchase agreements shall be reported in rows 100, 150, 200, 250, 300 and 350.According to the instructions (Annex V, Part 2, 91(a)) to template F 15.00, cash collaterals should be reported as repurchase agreement.There is a validation rule that partly ties the templates F 08.01 and F 15.00 together:v0912_m: {F 15.00.b, r190,c060} <= xsum({F 08.01.a, (r100, r150, r200, r250, r300, r350, c010-035)})Does it imply that cash collaterals also should be included in repurchase agreements in template F 08.01?

  • 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: 2014_1667
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Inconsistencies in FINREP validation rules F01.01 versus F04.03

According to F01.01 row 260 should be specified in table F04 (and F40). However, the validation rules v3390_i, v3394_i, v3398_i, do not permit this: v3390_i : {F 01.01, r070 , c010}=={F 04.01, r010 , c010} v3394_i : {F 01.01, r110 , c010}=={F 04.02, r010 , c010} v3398_i : {F 01.01, r150 , c010}=={F 04.03, r010 , c030} How should investments in Venture capital companies which are classified as Associated companies be reported?

  • 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: 2014_1666
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Inconsistencies in FINREP validation rules for Allowances and provisions for impaired debt instruments, defaulted guarantees and defaulted commitments (F31.01)

Validation rule v3974_s, says that in F31.01 row 130- Allowances and provisions for impaired debt instruments, defaulted guarantees and defaulted commitments [To be replaced by "Accumulated impairment, accumulated changes in fair value due to credit risk and provisions on non-performing exposures" when reporting of non-performing exposures would be final], should be reported with positive signs. Should row 130 include this rule of positive sign? We consider it should be able to report also with negative signs, for example instruments with amortised cost or FVO. v3974_s 2.0 (2013/09) Sign F 31.01 (020;030;040;050;060;070;080;090;100;110;120;130) (010;020;030;040;050)

  • 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: 2014_1665
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 26/06/2015

FINREP template 9.2

In FINREP template F 9.2 (Other Commitments Received) what is the nature of the Commitments to include in this section? Does non-mandatory commitments as per example promissory notes received or confort letters should be considered as part of this section?

  • 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: 2014_1661
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Large exposure reporting – Criteria for reducing the value of an exposure secured by commercial immovable property

Is Article 194(3)(b) relevant for accepting or rejecting commercial immovable property to reduce the value of an exposure secured by commercial immovable property according to the Article 402(2) when an institution uses the standardised approach for calculating credit risk capital requirements?

  • 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: 2014_1659
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 22/04/2016

Deduction of direct holdings of CET 1 instruments of FSEs

Article 45 of CRR specifies for the direct deductions in Article 36(1)(h) and (j) that we may calculate a net-long in the same underlying if positions are in the same book and has a contractual maturity of 1 year. Q1. Could a ‘short’ Total Return Swap (TRS) that hedges the economic risk of a long underlying position be included in the net-long calculation, such that it off-sets the direct deduction? Q2. Does the settlement convention of a TRS have any impact on the regulatory treatment (either/cash or physical)? Total Return Swaps are already mentioned in the definitions of synthetic holdings in Article 15b- of the ‘EBA FINAL draft regulatory technical standards on own funds [Part 3]’, however it remains unclear if this paragraph only constitutes definitions of long positions or whether they can net out. Q3. Could EBA confirm that a short synthetic holding could be netted if it is the exact opposite position of a long synthetic holding?

  • 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: 2014_1658
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 19/06/2015

Reporting transitional adjustments to RWA in C 05.01

We observe different treatments in practice on how transitional adjustments to RWA are reported in template C 05.01. From the reporting instructions we find two interpretations possible: that the whole amount of RWAs is reported or that only the adjustment compared to a fully loaded approach, per se, is reported.

  • 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: 2014_1657
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting of Liabilities against the initial margin and default fund

As per EBA/GL/2014/03 issued on 27 June 2014, it was stated that initial margin and default fund should be classified as encumbered. We would like to know how to determine the liabilities against those and report into F32.04.

  • 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: 2014_1653
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 19/06/2015

Definition of new funds and roll-over

What is the exact definition of rolled over funding and new funds.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1650
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Breakdown on funding C 70.00 Roll-over of funding

What division of funding types should we use, the one defined in the ITS, or the one defined in Annex III for C 70.00 Roll-over of Funding.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1649
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Reporting of Regulatory High Risk Items in default in C 09.01

Please can you advise how Regulatory High Risk exposures which are in default should be reported in C 09.01?

  • 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: 2014_1646
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Liquidity requirements: scope of applicability for investment firms

What are the prudential requirements for the following firms?a) investment firms that are authorised to provide the investment service referred to in point (3) of Section A of Annex I to Directive 2004/39/EC but are not authorised to provide the investment service referred to in point (6);b) investment firms that are authorised to provide the investment service referred to in point (6) of Section A of Annex I to Directive 2004/39/EC but are not authorised to provide the investment service referred to in point (3);c) investment firms that are authorised to provide both the investment services referred to in point (3) and (6) of Section A of Annex I to Directive 2004/39/EU.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1645
  • Topic: Other issues
  • Date of submission:

Is operational leasing included in annex 1 to Directive 2013/36/EU and shall it be included in a consolidated situation?

Shall companies that have operational leasing as activity be seen as a financial institution in Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No. 648/2012 (“The Regulation”) and should it be included in a consolidated situation?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1644
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 28/08/2015

Publication of gross or net positions for derivative transactions

In template B, should banks publish gross or net positions in the case of derivative transactions, where collateral could be posted and received between the two same counterparties?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/03 - Guidelines on disclosure of encumbered and unencumbered assets
  • ID: 2014_1640
  • Topic: Transparency and Pillar 3
  • Date of submission: