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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

Original Exposure Pre-Conversion factors

Should column 010 of CR SA (C 07.00), "Original Exposures Pre Conversion factors" be reported based on Secured/Unsecured part of the exposure?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1636
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Determination of client for large exposures purposes regarding exposures constituted by non recourse financing of leasing-SPEs

1. Can a financing transaction where the institution contractually agrees to abstain from recourse to its legal obligor to the extent that payment obligations of a third party (the lessee) to the institution’s legal obligor (the lessor) are not fulfilled, i.e. where the institution takes over the credit risk stemming from its obligors´claims against a third party, be regarded as “other transaction where there is an exposures to underlying assets” within the meaning of Article 390(7) of Regulation (EU) No 575/2013 (CRR)?2. Is it admissible to regard the structure of such a transaction as not constituting an additional exposure to the leasing-SPE or any other third party within the meaning of Article 390(7) CRR in connection with Article 7(1) of Regulation (EU) No. 1187/2014 , where a. the payment flows from the underlying asset to the investing institution are separated from the leasing-SPE, in a way that the exposures to the lessee are managed by the leasing-SPE, but the payments are made by the lessee directly to an account of the leasing-SPE kept at the institution on which the institution has a lien according to its general terms and conditions of business, and b. the SPE is bankruptcy remote, in particular according to the documented and detailed information available to the institution, the bankruptcy of the parent company should only have a negligible influence on the leasing-SPE?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1635
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of open ended funding products without a defined maturity

How do funding without a contractual maturity get reported in Additional Liquidity Monitoring Metrics? Should they be reported based on the most conservative approach?

  • 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_1633
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

General principle of C70 Roll-over of funding

Is C70 a look back report for the last month or is a cumulative reports for daily data?

  • 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_1632
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Validation rule original exposure pre conversion factors

According to the taxonomy the value of C08.01 field row 010 column 100 ('of which off-balance sheet items') should be equal to the value of field row 030 column 090 (Exposure 'off-balance sheet items subkect to credit risk'). In our view this is not correct as the field 030/090 excludes securities financing transactions and derivatives (as part articile 3.3.3.1) while the field 010/100 is for the whole portfolio.

  • 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_1631
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Treatment of Financial offsetting of assets and liabilities subject to offsetting, enforceable master netting arrangements and similar arrangements'

How does the assets/liabilities balances subject to netting are reported and how does the associated collateral with it reported are reported in F 32.04 ? How does the assets (on and off) are reported on FR 32.01 and FR 32.02 ?

  • 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_1630
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/06/2021

Validation Rules v4047_m to v4055_m for CR SEC SA

The validation rules v4047_m to v4055_m check on the plausibility of the percentages given in column 300 of CR SEC SA. To this end the rules refer to columns 300 and 290 of CR SEC SA of various rows. We believe these rules should use column 280 instead of column 290.

  • 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_1629
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/06/2016

Eligibility as collateral where securitisation positions are issued by an SSPE belonging to the same group

What group entities are considered as “related” to the obligor for the purpose of the second sub-paragraph of Article 207(2) of Regulation (EU) No 575/2013 (CRR)? In particular, does this apply to securitisation special purpose entities (SSPE)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1628
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 10/03/2017

Scope of deposit monopoly

According to Article 9(1) of Directive 2013/36/EU (CRD), only credit institutions can carry on the business of taking deposits or other repayable funds from the "public". Will the operation of a group account arrangement within an industrial group - which, inter alia, requires a subsidiary to deposit funds with its parent company - breach the deposit monopoly in Article 9(1) of the CRD? The purpose of such a deposit requirement is generally to optimise the liquidity management within the group. The arrangement only applies to subsidiaries within the group.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1626
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Sign Convention

Column 030 in C 07.00 (-) VALUE ADJUSTMENTS AND PROVISIONS ASSOCIATED WITH THE ORIGINAL EXPOSURE) has negative sign, while in C 09.01 columns 050to 070 has (+) sign convention. We would like to know that what is the rationale behind having different sign convention for same fact?

  • 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_1625
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

HANDLING OF CASH COLLATERAL DEPOSIT HELD WITH OUR BANK

Bank A is solo reporter and is a small subsidiary bank owned by foreign Government of (Third) country X (51%) and Bank A (49%). In the General ledger it has a loan to a Public Sector Enterprise incorporated in the (Third) country X. This loan is backed by cash collateral provided to Bank A by the Central Bank of the (Third) Country X which covers the outstanding balance (principal) on the loan fully - only the interest remains uncovered.How shall this loan and the linked deposit be reported for liquidity purposes in the LCR templates (C 52.00 / C 53.00)?Operationally, the deposit is expected not to generate any additional liquidity buffer requirement as the deposit is expected to be returned only when the loan is fully paid, thus covering the expected outflows by the inflows.

  • 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_1624
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

FINREP

According to the Financial Conduct Authority in the United Kingdom, only groups that report under International Financial Reporting Standards (IFRS) are subject to FINREP. However, the EBA has issued templates and instructions for groups that report under National GAAP. Therefore the EBA is indicating that groups must submit FINREP reports regardless of whether they report under IFRS or National GAAP. Please advise if groups reporting under National GAAP are required to provide FINREP submissions.

  • 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_1621
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Applicability of Article 423(1) of the CRR for intermediaries facilitating derivatives clearing between its clients and a CCP

Is it permissible for an institution, for which the following is true, not to apply the additional outflow required under Article 423(1) of Regulation (EU) No 575/2013 (CRR): (i) the institution acts as a financial intermediary in the meaning of Article 303 of the CRR between a client and a central counterparty (CCP) in order to facilitate the central clearing of the clients’ derivatives (as e.g. required in the future by Regulation (EU) no 648/2012 (“EMIR”)); and (ii) it is contractually assured that the institution immediately receives collateral from its clients in case the value of the collateral posted to the institution as margin for its set of derivatives channelled through this intermediary to the CCP is not sufficient to cover the CCP’s margin requests for the set of derivatives.

  • 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_1619
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 10/07/2015

Definition of financial corporates for Leverage Ratio and FinRepITS

Is the definition of financial corporates really different in the Leverage Ratio and FinRep ITS?

  • 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_1618
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Specialised Lending Supervisory Slotting Method and CRM Substitution Approach

1) Can the CRM substitution method be used for specialised lending exposures when the supervisory slotting method is applied under the CRR?2) If this answer is yes, can we request that the relevant cells in template C8.01a (i.e. columns 70 and 80) are opened for rows 90-150 to allow banks to report this information correctly?

  • 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_1604
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Treatment of cash at bank under the large exposures regime

According to EBA Question ID 2013_412, "cash" positions do not fall under the scope of the large exposures regime and do not need to be reported.1)      Could you please confirm whether cash at bank deposited by an investment firm fall under the large exposures regime?2)      Could you please also provide us with the relevant reference in the CRR which states that cash positions are excluded from the large exposures regime?3)      When you are referring to "cash" positions do you include both cash held at hand and at bank?If indeed cash deposits are considered in the calculation of large exposures, where these should be reported in the C 28.00 and C 29.00 templates?

  • 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_1598
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Directorships

What is the correct interpretation of Article 91 (4) b) ii) of CRD IV setting the rules for quantifying executive and non-executive directorships within undertakings in which the significant institution holds a qualifying holding? i. An individual holding directorships in four undertakings in which the significant institution holds a qualifying holding will be treated as one single directorship with the directorship held within the significant institution being treated as a separate directorship. ii. An individual holding directorships in four undertakings in which the significant institution holds a qualifying holding with the directorship held within the significant institution not being treated as a separate directorship.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1595
  • Topic: Internal governance
  • Date of submission:
  • Published as final Q&A: 13/11/2015

Exemptions from the application of Article 395(1)

Could exposures of an institution fully guaranteed by its parent undertaking - considering the substitution approach under Article 403(1)(a) of Regulation (EU) No 575/2013 (CRR) – be exempted from the large exposures provisions and in this way from the application of Article 395(1)? Furthermore, may the guarantees provided by the parent institutions from another Member State be handled in Article 403 of the CRR as a third party guarantee?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1592
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 10/07/2015

Aggregate Liabilities

Where wholesale funding issuance is undertaken in a currency which is different to the base reporting currency of the institution, and on issuance is swapped back for the duration of the liability (therefore leaving the institution with no currency risk on the transaction), does this issuance count towards the aggregate liabilities cap for single currency reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1579
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/02/2015

LCR Inflows: current accounts with other credit institutions

Article 425(2)(c) of Regulation (EU) No 575/2013 (CRR) specifies that assets with an undefined contractual end date shall be taken into account with a 20% inflow provided that the contract allows the institution to withdraw and request payment within 30 days. Do current accounts held with other credit institutions fall into that category? If not, how should these current accounts be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1576
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/02/2015