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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

Meaning of "credit lines" in the context of conversion factors for certain off-balance sheet items

Which types of off-balance sheet exposures are referred to by the term “other credit lines” in Article 166(8)(d) CRR? Specific clarification is requested (i) for long-term letters of credit arising from the movement of goods, as only such short-term letters are mentioned in Article 166 (8)(b) CRR, and (ii) for guarantees.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2663
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Exemption from cap of inflows per Article 33 (1) of the Commission Delegated Act 2015/61

(a) Can the national competent authority of a Member State grant such exemption where the inflow arises from the parent companies or subsidiaries incorporated in third countries?(b) If the reply to the first question is positive, shall the national competent authority carry out an assessment as required under the draft regulation to be issued by the ECB under Article 425(5) of the CRR and Article 34(1)(2) and (3) of the Commission Delegated Regulation (EU) 2015/61 or shall the national competent authority follow other national guidelines?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2660
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 23/09/2016

Scope of C40 LR1 Row 090

Is the scope of LR1, row 090 (‘Other assets’) limited to off-balance sheet assets; or should the scope given for row 090 in Annex XI take precedence over the restrictions in Paragraph 21 of Annex XI?And if the latter, please confirm if each of the following assets must be included in LR1 Row 090:i) Trading book positions;ii) Unsettled trades.iii) Default fund contributions.

  • 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: 2016_2659
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 04/10/2019

AVA calculation and tax effects

Should Additional Value Adjustments (AVAs) be calculated net of tax effects for the purpose of the CET1 deduction in Article 34?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2016_2658
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 25/05/2017

Identification of Material Risk Takers in branches of a Member State institution, where the branch is established in another Member State

Where an institution (established in a Member State) has established a branch in a different Member State, is the branch to be treated as having to identify its material risk takers in accordance with Commission Delegated Regulation (EU) No. 604/2014 on an individual basis, or should the branch be treated as a business unit of the institution? Similarly, in relation to an institution established in a Member State, does a branch established in a third country need to identify its material risk takers on an individual basis, or should the branch be treated as a business unit of the institution?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2016_2655
  • Topic: Remuneration
  • Date of submission:

Recognition of minorities arising from an intermediate financial holding company

In the example below, are the minority interests of 20% in (mixed) financial holding company no. 1 – after applying the deductions according to Article 84 CRR – eligible for the consolidated own funds of the group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2652
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Aircraft loans as collateral for covered bonds

Are aircraft loans eligible as collateral and as a consequence credit quality step 1 in the case explained in the background or do they not receive the preferential treatment or otherwise are they non-eligible for LCR in every case?

  • 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: 2016_2651
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 22/09/2017

Capital requirement regard to own debt instruments.

Should institutions encounter own debt instruments in calculating own funds requirements for position risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2648
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Operational Deposits Arising From The Provision of Operational Services (Clearing, Custody and Cash Management)

How should firms assess/identify the presence of 'operational limitations that make significant withdrawals within 30 calendar days unlikely' and the level of funds that are 'required for the provision of operational services'?

  • 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: 2016_2647
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Risk weight for exposures to central-government-risk PSEs with an original maturity of 3 months or less, which are denominated in foreign currency

May exposures to PSEs established in a Member State, whose level of risk in the opinion of the competent authority of the Member State in question does not differ from the level of risk of the central government, be assigned a risk weight of 20% in accordance with Article 116(3) CRR if they are denominated in foreign currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2646
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Maturity Bucket of Call Deposits for Large Exposure Reporting

What is the correct maturity bucket to report call (on-demand) deposits in Large Exposure Reporting template LE4?

  • 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: 2016_2644
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Definition of a 'Deposit Broker'

What is the definition of a deposit broker?

  • 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: 2016_2642
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 23/09/2016

Risk weighting under the Standardised Approach for credit risk for an exposure secured by a mortgage on a residential property which is a second home (for instance, a holiday home).

Can a second home be a residential property under Article 4(75) of Regulation (EU) No 575/2013 (CRR) and thus a respective mortgage benefit from the 35% risk weight under article 125(1)(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2641
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Relevant competent authority to determine the same risk weight treatment as the central government

Who is the relevant competent authority to determine if the same treatment of regional government exposure and central government exposure can be applied? The national supervisor, the European Commission or the ECB?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2637
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Mark-to-Market Method: Residual Maturity for Physically Settled Contracts

Which maturity should be used to determine the percentage as per Table 1 in Article 274(2) of Regulation (EU) No 575/2013 for derivative instruments that are settled with cash instruments for which a maturity can be determined, e.g. a cash debt security? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2634
  • Topic: Market risk
  • Date of submission:

Validation rules EBA_V4399 and EBA_V4400 warning on the tables P 02.04 and P 02.05

The Annex I of the "Guidelines on harmonised definitions and templates for funding plans of credit institutions under recommendation A4 of ESRB/2012/2" contains disclosure tables for pricing of Loan Assets "Table 2B1 (P 02.04)" and pricing of Deposit Liabilities "Table 2B2 (P 02.05)". Validation rules EBA_V4399 and EBA_V4400 check if the figures submitted are greater than or equal to zero. The "Guidelines on harmonised definitions and templates for funding plans of credit institutions under recommendation A4 of ESRB/2012/2" defines the data to submit as follows: - The projection of high-level yields on assets, with a 1-year horizon. Firms should report the all-in yield received/paid and should not report a spread. - Projection of high-level costs of funding, with a 1-year horizon As this tables aim to provide interest rates and as interest rates could be negative, we think that the validation rules V_4399 and V4399 should be adjusted.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2633
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 05/10/2018

Calculation of derecognised fiduciary assets

Are institutions required to calculate the value of their fiduciary assets in accordance with the leverage ratio framework even though the assets are already derecognised pursuant to Article 429a(1)(i) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2016_2631
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Validation rule v4574_m

Is validation rule v4574_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)
  • ID: 2016_2630
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Treatment of decreases of impairments in the calculation of the exposure value

In the context of published Q&A 2014_1087 how should a credit institution treat decreases of impairments, value adjustments or provisions (in case of reduced identified losses) recognised during the year, i.e. in the interim period, in the case where the competent authority has not given its permission to include the interim profit into the calculation of Common Equity Tier 1 capital, and the credit institution has not reflected the amounts with a corresponding "immediate reduction in Common Equity Tier 1 capital" although the changes in impairments, value adjustments or provisions for off-balance sheet items are reflected in interim profits or year-end profits?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2016_2629
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 23/09/2016

Asset encumbrance Reporting vs. Finrep Reporting – Definition of equity instruments not aligned

The following validation rule is not correct:v2816_m: sum({F 32.01, r030, (c010, c060)}) = sum({F 01.01, c010, (r070, r093, r110, r150, r172, r176, r235)})’.This validation rule excludes row 260 of F 01.01. An entity has to disclose ‘Investments in subsidiaries, joint ventures and associates’ in this row.By definition, row 260 of F 01.01 includes equity shares that are representing the ownership in subsidiary, joint ventures or associates.

  • 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: 2016_2628
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/08/2017