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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

Implementation of default definition - retail portfolio

In the case of retail exposures, can the default definition be implemented in a way that the default of an exposure secured by mortgage extends to unsecured facilities, but not the other way round?Alternatively, should a bank implement the default definition within the retail non SME portfolio consistently at the level of facility, i.e. at the level of product type without extending the default to other facilities?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2968
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/05/2017

Section 3(a)(2) guarantees - eligibility for MREL

Can debt securities issued under a Section 3(a)(2) bank note program where the guarantor is a branch of the issuer be deemed to meet the criteria of article 45 of the BRRD in order to be included in the amount of own funds and eligible liabilities?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2966
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 27/10/2017

Reconciliation of FINREP and COREP with regard to goodwill

May the amounts of goodwill reported in FINREP and COREP differ due to differences in treatment between the accounting framework and the CRR?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2963
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Reporting of Treasury bills (henceforth T-bills) in template F 01.01

Where should T-bills be reported in template F 01.01 – Balance Sheet Statement?

  • 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_2962
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Risk retention and credit risk mitigation

If the Originator retains a vertical slice of a securitisation capital structure the most senior tranche of which is guaranteed - as part of the original securitisation structure - by a third party guarantor, would that be in contrast with the requirement as set out in paragraph 1 of Article 405 of CRR, providing that the net economic interest shall not be subject to any credit risk mitigation or any short positions or any other hedge and shall not be sold.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2960
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Difference between a reduction and a write-down

What is the difference between reduction and a write-down in Article 60(1)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2958
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Difference in treatment of viable subsidiaries for the application of write down and conversion of capital instruments and resolution tools and powers

Can the power of write down or conversion of capital instruments be exercised in relation to instruments issued by a still viable subsidiary belonging to a failing group?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2957
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as final Q&A: 21/01/2022

PONV write-down leaving an institution failing or likely to fail

Do capital instruments and liabilities eligible for internal MREL (minimum requirement for own funds and eligible liabilities) always have to be written down or converted through the application of the point of non-viability (PONV) write-down prior to bail-in?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2956
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as final Q&A: 18/11/2016

Write down of capital in BRRD and CRR / CRDIV

What is the relationship between the powers of the resolution authority following the BRRD to write down capital and the provisions in CRR / CRD IV allowing the competent authority to write down capital?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2955
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as final Q&A: 18/11/2016

Interpretation of consolidated prudential requirements

How should the reference to "consolidated prudential requirements" in Article 59(6) be interpreted?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2954
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as final Q&A: 18/11/2016

Exclusion of corporate deposits

Can corporate deposits be excluded from bail-in in the context of Article 44 of the BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2953
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Application of 8% requirement to group resolution

Should the contribution to loss absorption and recapitalisation be calculated with reference to the liabilities of the holding company being bailed in, or the liabilities of the failing subsidiary or subsidiaries?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2952
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Exclusion of securities guaranteed by an independent on-demand guarantee from bail-in

Can securities guaranteed by an independent on-demand guarantee be considered as "otherwise guaranteed" claims mentioned in Recital (70) of Directive 2014/59/EU (BRRD) and as such be excluded from bail-in?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2951
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Review and validation of criteria for the use of a reduced number of parameters

For purposes of internal independent review and annual validation of the netting methodology, can the testing be based on historical data from the most recent 100 trading days for the same or similar valuation inputs?

  • 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_2949
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Valuation input consisting of a matrix of parameters

For the purposes of calculating AVAs for Market Price Uncertainty, where a valuation input consists of a matrix of parameters (for example a curve or a surface), can the AVAs be calculated at the level of the matrix as a whole (i.e. the curve or surface) based on the valuation exposures related to each parameter within that matrix, rather than be calculated at the individual parameter level?

  • 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_2948
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Model selection/use in context of a pending application of a significant model change

Should an institution that expects to receive approval to use a new internal market risk model following the remittance of IMVs but prior to the remittance of the risk measures submit IMVs using the old model or new?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2946
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Reporting LR2 - exposures to consider?

In Template CRD41 / LR2, shall we include or exclude derivatives and SFT's in the exposures distributed by risk weighted? The regulation is focusing on ON and OFF balance sheet items while the title of the Template mention "Total on- and off-balance sheet exposures belonging to the banking book as well as exposures of the trading book subject to counterparty credit risk (breakdown in accordance with the risk weight):".

  • 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_2945
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Annex V, Section 2.4: Market Benchmarking Portfolios. Definition of Portfolio 16 (FX)

Please confirm that the NYC Closing on 13 October 2016 should be used for the determination of the barrier.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2942
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Annex V, Section 1: Market Benchmarking Portfolios. Definition of Portfolio 13 (FX)

For consistency we will also use the EUR/USD ECB reference rate for the option in portfolio 13. Please confirm that this is appropriate.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2941
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Annex V, Section 1: Market Benchmarking Portfolios. Definition of Portfolio 10 (IR)

We will use 16 October 2018 as start date for the swap and thus 14 October 2018 as maturity of the option. Please confirm that these dates are appropriate.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2940
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission: