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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

Annual Contribution of institutions - determination of the basis for annual contributions and the risk weight / use of CRDIV/CRR terminology

What information / data shal be used when determining the annual contributions to resolution financing arrangements in situations, where information required by specific indicators as referred to in Annex I and II of DA is not included in the applicable supervisory reporting for the reference year, e.g. due to inapplicability of the CRDIV/CRR?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1926
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 24/07/2015

Annual contribution of institutions newly supervised, institutions non existent in the reference year for contribution calculation, and institutions that ceased to be supervised

How to apply a requirement of the Article 12 of DA to determine a partial contribution calculated during subsequent contribution in case newly supervised institutions, institutions that ceased to exists / be supervised, and the institutions that were not existent in time in the reference year for contribution calculation as detailed in Article 14 of DA?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1925
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 13/05/2016

Exclusion of Intragroup Liabilities -Treatment of intra-group derivative contracts

How to apply requirement of Article 5 (4) to substitute any accounting value of liabilities arising from derivative contracts by a corresponding value determined in line with Article 5 (3) and possibility to exclude specific intra-group liabilities according to Article 5 (1) a)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1924
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 30/10/2015

Exclusion of Intragroup Liabilities - General Rule

"Does the criterion of Article 5 (1) a) ii) of DA ""each institution is included in the same consolidated supervision according to Artices 6 to 17 of Regulation No 575/2013 (EU) on a full basis"" alows also intragroup liabilities between ""sister"" companies to be excluded while calculating individual ex ante contributions to resolution arrangements?"

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1923
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 24/07/2015

Exclusion of Intragroup Liabilities -Treatment of cases when one institution pays annual contribution according to Article 10 of DA (lump sum) and the other according to standard risk-weight reflecting approach

How to apply requirement of Article 5 (1) (a) to exclude intragroup liabilities arising from transactions between institutions where one party to the transaction qualifies for lump-sum contribution in line with Article 10 of DA?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1922
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 13/05/2016

Basis for ex-ante contributions to resolution financing arrangements

What does Article 103(2) of BRRD mean by the requirement to ”exclude own funds” from the liabilities of institutions when determining the ex-ante contribution to resolution financing arrangements?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1921
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 24/07/2015

Calculation of unsecured and secured parts of past due items – Standardised approach

Under the standardised approach, when calculating the unsecured part of the exposure for the purpose of computing provisions threshold (20%) under Article 127(1) of the CRR, shall the exposure exclude eligible financial collateral and credit protection that comply with the requirements stated in Part Three, Title II, Chapter 4 of the CRR, ‘Credit Risk Mitigations’, as well as residential real estate and commercial real estate as described in Article 127(3) & (4) of Regulation (EU) No 575/2013?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1918
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/04/2016

Eligibility of unconditional Financial Letters of Credit as eligible financial collateral

Can an unconditionally drawable Letter of Credit held by an institution as beneficiary be treated as a “cash assimilated instrument” eligible for inclusion by that institution as an item of Funded Credit Protection against an outstanding exposure position for a contingent future payment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1917
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Reporting on Stable Funding

Article 427(1) of Regulation (EU) No 575/2013 (CRR) requires institutions to report on Stable Funding in accordance with the reporting requirements set out in Article 415(1) and the uniform formats referred to in Article 415(3). Therefore is it correct that Article 415(2) is not a requirement of Stable Funding reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1912
  • Topic: Liquidity risk
  • Date of submission:

Eligibility of religious communities or churches

Are churches or religious communities eligible protection providers under all approaches and thus included in the list of providers of Article 201 with reference to paragraph 1(b)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1908
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/12/2015

How the various types of sight deposit are to be treated in ALMM templates C68.00, C69.00 & C70.00, and whether it is possible to achieve a consistent treatment given the differences in requirements across these templates.

How are the three types of sight deposit (current accounts, instant access savings and term-less cash ISAs) to be treated in templates C68.00, C69.00 & C70.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1901
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Validation Rules v0677_m, v0678_m and v0726_m for Leverage Ratio

Are the following validation rules for leverage ratio reporting despite the Delegated Regulation (EU) 2015/62 still applicable? v0677_m {C 43.00.a, r010,c010} = sum({C 45.00.a, c030, (r060-090)}) v0678_m sum({C 43.00.a, c010, (r040-060)}) = sum({C 45.00.a, c030, (r010-050)}) v0726_m {C 45.00.a, r100,c030} = {C 43.00.a, r070,c010} + sum({C 43.00.b, c010, (r080-090, r140, r180-190, r210, r230, r280-290)}) + sum({C 43.00.c, c020, (r080-090, r140, r180-190, r210, r230, r280-290)})

  • 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: 2015_1899
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 14/08/2015

Own funds – Share premium accounts

There is an agreement for transfer of profit and coverage of losses (i.e. Profit and Loss Transfer Agreement, PLTA)  between the credit institution in question and its mother credit institution, therefore the shares of the credit institution are in the future no longer eligible as a CET1 items (confer Question ID 408/2013 – now archived). In conjunction with the out-phasing of these shares pursuant to the transitional provisions in Article 484 ff CRR, the questions arises if the share premium accounts also have to be out-phased or if they are still eligible as CET 1 instruments according to the provisions laid down in Article 485 para. 2 CRR.Are the conditions set out in Article 28 para. 1 letter (i) CRR met, if a credit institution has also (in addition to CET 1 instruments) T2 instruments which may be repaid before liquidation only with a proportional deduction of the net losses incurred during its lifetime?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1895
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/11/2015

Reporting of retail deposits that qualify for the treatment set out in Article 421 (5a) CRR

Is it possible to report retail deposits defined in Article 421 (5a) CRR in the same way as deposits under Article 421 (1a,2) CRR for the Net Stable Funding Ratio purposes?

  • 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: 2015_1894
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Treatment of specific liabilities - even deduction

What does Article 5(2) of the Commission Delegated Regulation (EU) 2015/63 mean by the requirement to “evenly deduct” certain liabilities? Could you please provide any examples?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1893
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 22/05/2015

The maturity ladder on template AE-CB (F 35.00)

Do institutions need to report the residual maturity of the cover pool assets or the residual maturity of the covered bonds the assets are backing in the maturity ladder of the Cover Pool Assets (C 150-C 200)?

  • 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: 2015_1891
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Treatment of an asset resulting from obligatory payments to Deposit Guarantee Scheme in Risk Weighted Assets calculation (Standardised Approach).

How should an asset resulting from prepayment of obligatory contribution to Deposit Guarantee Scheme be treated for the purpose of credit risk capital requirements calculation under the Standardised Approach?Should it be recognised as ‘Other assets’ (prepayments to unknown counterparty) or as an exposure to the Deposit Guarantee Scheme?Moreover, if the recognition as an exposure to the Deposit Guarantee Scheme is correct, is it possible to treat the Deposit Guarantee Scheme as a Public Sector Entity which can be treated under Article 116(4) CRR, and therefore assigned a 0% risk weight?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1890
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Initial margin for the purpose of hypothetical capital calculation

What amount should be used as the initial margin posted by to the Central Counterparty (CCP) by a clearing member for the purpose of Article 50a of Regulation (EU) No 648/2012 (EMIR), introduced by Article 520 of Regulation (EU) No 575/2013 (CRR)? Does the Article 50b(c) of the EMIR apply to the initial margin? Should the excess initial margin be included?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1889
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 21/08/2015