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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

Groups of connected clients when a client is connected through various criteria (interconnection through control and / or economic interconnection)

As defined in Article 4(1)(39) of Regulation (EU) No 575/2013 (CRR), clients can be included into ‘groups of connected clients’ through criteria of control (Article 4(1)(39)(a)) or economic interconnection (Article 4(1)(39)(b)).What is the correct treatment of exposure to a client in case when the client is connected with other natural or legal persons through criteria of control and / or economic interconnection?Should the institution include and report all those clients connected with particular client as one ‘group of connected clients’ regardless of criteria of connection (control vs. economic interconnection) or should the institution include and report particular client in two (or more) groups where one group includes clients that are connected with particular client through criteria of control and the other separate group (or more groups) is formed of clients that are connected with particular client through criteria of economic interconnection?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1443
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 24/11/2017

Reporting the income or expense resulting from the recalculation of the carrying amount of the financial asset or financial liability as prescribed by IFRS 9.B5.4.6.

Our question is where (under what item) should be presented in the template F 02.00 “Statement of profit or loss” the income or expense resulting from the recalculation of the carrying amount of the financial asset or financial liability as prescribed by IFRS 9.B5.4.6. Furthermore, it would be helpful for us to have your confirmation that the respective adjustment is deducted when presenting the gross carrying amount of the financial asset.

  • 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
  • ID: 2014_1441
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

Securities Lending

In the guidance on asset encumbrance Annex XVII, chapter 2.1.1, paragraph 14 (d) it states that ‘where the securities lent as collateral are received by the reporting institution, their fair value is reported in {AE-COL; *; c010}, {AE-SOU; r150; c030} and {AE-SOU; r150; c040}’.However, {r150; c040} is greyed out in template F 32.04.Please advise whether this data point will be available for input. 

  • 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_1431
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 28/07/2017

Recognition of contractual netting agreements by the competent authority

Should the provision of Article 296(1) of Regulation (EU) No 575/2013 (CRR) that “competent authorities shall recognise a contractual netting agreement …” be understood as a requirement to have an acceptance made by the supervisory authority, in particular in the course of performing its on-site or off-site activities, or rather to receive a formal permission (e.g. in a form of an administrative decision) of a competent authority?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1424
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 12/12/2014

Internal model for correlation trading

For an internal model for incremental default risk and migration risk “an institution may choose to consistently use a one-year constant position assumption.” (Second sentence of Article 374 (4) of Regulation (EU) No 575/2013 (CRR)). Does an institution also have this choice for an internal model for correlation trading?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1422
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 19/12/2014

Row 030 C07.00 reported also for exposure class of protection provider

Should the part of the "eligible" SME exposure according to Article 501 CRR that is secured with e.g. guarantee be reported in the row 030 (C07.00) in the exposure class of the guarantor and also be subject to the supporting factor?

  • 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_1419
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Significance of the term ‘without prejudice’ in Article 86 of Regulation (EU) No 575/2013 (CRR)

Article 86 of Regulation (EU) No 575/2013 (CRR) sets out a general principle of limitation of minority interests / external resources on Additional Tier 1 capital. This article explicitly provides that this limitation is ‘without prejudice to Article 84(5) and (6)’. Article 84 of the CRR sets a principle of limitation of minority interests in the computation of consolidated Common Equity Tier 1 (CET1) capital. However, the exception under Article 84(6) CRR allows institutions to recognise all minority interests when included in the scope of an Institutional Protection Scheme (IPS) completed with a cross-guarantee scheme. Does the term ‘without prejudice’ mean that the exception for CET1 capital provided for in Article 84(6) can be applied by analogy to the instruments of Article 86 in order to avoid a partial recognition on the Additional Tier 1 capital.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1415
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 26/06/2015

Groups including investment firm(s) referred to in Article 95(1) and investment firm(s) referred to in Article 96(1) and not including credit institutions.

What method of calculating the own funds requirement should be used when a group consists of both 95(1) and 96(1) investments firm and no credit institutions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1414
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Balance Sheet Netting as a CRM technique

Is Balance Sheet Netting according to Article 195 limited to Cash Balances in the same currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1413
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Refinancing

Does a derecognition on an institution’s balance sheet of a forborne contract lead to an end of the forborne exposure and end to reporting duty?

  • 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_1412
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Embedded forbearance clauses

Does it lead to a forborne status of the contract if executing embedded forbearance clauses (e.g. payment holiday and partial write off), incorporated in Dutch Nationale Hypotheek Garantie mortgages?

  • 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_1411
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Group Solvency report: The content of the column 390 “Contributions to consolidated result” of the Group Solvency report

Does the content of column 390 “Contributions to consolidated result” of the Group Solvency report correspond with the row 130 “Retained earnings” of the CA1 report (C 01.00) on group level (subgroup level) or rather with the sum of the rows 280 “Cumulative gains and losses due to changes in own credit risk on fair valued liabilities” and 285 “Fair value gains and losses arising from the institution's own credit risk related to derivative liabilities” of the CA1 report on group level (subgroup level)?Expressed as formulas: {GS;c390} = {CA1;r130} or {GS;c390} = {CA1;r130} + {CA1;r280} + {CA1;r285}? (Regulation (EU) No 680/2014 [ITS on Reporting], Annex II, C 06.00, c390)

  • 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_1398
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Group Solvency report: The distinction between the contents of the columns 350 “Goodwill / Negative goodwill” and 400 “Goodwill / Negative goodwill” of the Group Solvency report

To what extent the contents of the columns 350 “Goodwill / Negative goodwill” and 400 “Goodwill / Negative goodwill” differ from each other? Does the content of the column 400 “Goodwill / Negative goodwill” of the Group Solvency report correspond with the row 300 “Goodwill” of the CA1 report on group level (subgroup level) in case of goodwill (not negative goodwill)? Furthermore, does the content of column 350 “Goodwill / Negative goodwill” of the Group Solvency exclusively concern the goodwill / negative goodwill referring to minority interests? (EBA/ITS/2013/02, Annex II, C 06.00, c350, c400, pp. 59, 60)

  • 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_1397
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Group Solvency report: Reporting of the columns 300 to 350 and columns 360 to 400

Shall a consolidated entity which contributes to the group’s consolidated own funds by minority interests but also by other means exclusively report columns 300 to 350 or additionally columns 360 to 400? (Regulation (EU) No 680/2014 (ITS on Reporting), Annex II, C 06.01 / C 06.02, c300 to c400)

  • 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_1396
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

COREP validation rule v3691

When the AT1 adjustment on Minority Interest (fully loaded) as reported in C05.01 c060; r091 is a positive figure, the transitional recognition hereon (C05.01 c020; r091) must then be negative. While the validation rules on columns 060 and 030 (resp. v3692 and v3693) have been de-activated on 23/03/14, we do not see why the validation formulae regarding column 020 (v3691) remains applicable.

  • 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_1395
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Validation rule v3694_s - v0532_m

During the validation of the C13 and C05.02 (Corep own funds and leverage, consolidated on prudential basis we obtained a validation), performed by our regulator, we obtained a validation error that is incorrect, namely: v3694_s Sign C 05.02 (010;020;090) (020;030;040;060) {C 05.02} >= 0 do not run rule The correction in C05.02 does not only reflect the temporary inclusion of subordinated loans which don’t fulfill the requirements of CRR / CRD IV, but should also reflect the temporary transfer of old-style hybrids to AT1 in a phased approach. When the old-style hybrid instruments fulfill the conditions to be recognized as Tier 2 capital under CRR/CRD IV, these instruments are taken into account in the fully loaded reporting as reflected on line {C01.00,r760,c010). However in a phased-in calculation, which is reported under the transitional measures, these instruments can temporarily still be recognized as Additional Tier 1 instrument. Therefore, the transitional adjustment related to Tier 2 will imply a decrease of Tier 2 capital and recognition as Additional Tier 1 capital (in 2014 only 20% remain in T2 and 80% will be transferred to AT1, in 2015 40% will stay in T2 and 60% will receive recognition as AT1, …) and thus the correction to be made to Tier 2 is negative. v0532_m: (c190) = (c200) + (c210) + (c220) + (c230) + (c240) + (c250) + (c260) + (c270) + (c280) + (c290) + (c300) + (c310) + (c320) + (c330) + (c350) + (c370) [[C 13.00 (r010-150;170-540)]] (1 error(s)) We assume that validation check in table C13 on field W51 (Exposure value subject to risk weights) is erroneous. The value in this field should totalize all exposure values in the fields from X51 till AI51 (ratings based method) plus AJ51 (unrated), AK51 (supervisory formula), AM51 (look- through) and AO51 (internal assessment approach). It’s however impossible to meet this requirement, since the fields from AK51 till AQ51 are blocked.

  • 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_1388
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Treatment of subordinated loans in respect of Art 133 (3) CRR

Could you please confirm that subordinated loans according to Art 62.a CRR, which are acknowledged as Tier 2 are not regarded as equity exposures according to Art. 133.3 CRR.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1384
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Short positions in financial institution capital instruments

(1) Where a bank holds an item which is treated as a financial institution capital instrument under CRR, can a guarantee or credit default swap over that instrument be considered a short position for the purposes of Articles 45(a), 59(a) or 69(a)? (2) Where a bank has an indirect holding of a financial institution capital instrument, can a guarantee or credit default swap over the host item be considered a short position in the underlying capital instrument for the purposes of Articles 45(a), 59(a) or 69(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1382
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 20/02/2015

PD substitution and eligibility of guarantors

Article 202(d) of Regulation (EU) No 575/2013 (CRR) suggests that where risk weighted exposure amounts are calculated under the IRB Approach, a guarantor must have an internal rating in order to be eligible as a guarantor for PD substitution. Can a guarantor, which is rated by an ECAI, and otherwise meets all eligibility requirements but is treated under the Standardised Approach by the institution, be used for PD substitution? How can a guarantee be recognised in this situation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1381
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/09/2015

Disclosure requirement on individual basis

What is the connection between the provisions of Article 13 and Article 433 of Regulation (EU) No 575/2013 (CRR)? When shall the institutions disclose all the information required by Part Eight and on what condition could the limited disclosure requirement be applied on individual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1379
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 27/03/2015