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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.

List of Q&A's

Calculation of goodwill included in the valuation of significant investments in insurance undertakings

A. For the purposes of a deduction under Article 36(1)(b) CRR as per Article 37(b), should the goodwill (Article 4(1) no. 113 and 115 CRR) included in the valuation of significant investments calculated excluding goodwill booked under an insurance subsidiary given that this goodwill is not included in the valuation of a significant investment of the bank (i.e. goodwill not included in the prudential consolidation as per Articles 1, 11, 18 and 24 of CRR and EBA RTS on the methods of prudential consolidation)?  B. Can you confirm that the goodwill booked under an insurance subsidiary (which is excluded from the valuation of significant investments as per prudential consolidation) should be treated as part of the equity exposure of the bank to the insurance subsidiary and this be risk weighted as per Article 49(1) and Articles 133 or 155 (depending on Standardized or Advanced IRB method)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition and scope of Asset Under Management

Are assets for which the investment firm provides account aggregation services (outside of the MiFID authorisation scope) to be included in the AUM calculation?  

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C34.09 Credit Derivative Exposures – Signage of positive and negative fair values for credit derivatives

The instructions provided in Annex II Reporting on own funds and own funds requirements for template C34.09 requires the fair values broken down by product type as well as assets (positive fair values) and liabilities (negative fair values). According to validation rules v10325_s and v10481_s for C34.09, the fair values reported in columns 0030 and 0040 for rows 0010 to 0070 must be greater than or equal to zero. Can the EBA clarify if positive fair values should be reported with positive signage and negative fair values should be reported with negative signage in rows 0010 to 0050? Or if the validation rules are correct then is the requirement to report both positive and negative fair values with positive signage in these rows?  

  • 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

C34.01 Size of the Derivative Business – Application of validation rule v09805_m

The instructions provided in Annex II Reporting on own funds and own funds requirements for template C34.01 states the size of the derivative business must be the sum of the absolute value of long derivative positions and absolute value of short derivative positions.  According to validation rule v09805_m applicable to row {0050} in the C34.01 template, the percentage of the total assets to the size of the derivative business must be less than or equal to one.  Taking the sum of the absolute market value of long and short derivative positions would most likely trigger this warning validation. Can the EBA review the warning validation rule v09805_m for C34.01 and confirm if this needs amendment? 

  • 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

Upcoming deals in Liquiity risk reporting

Our institution currently reports the LCR including only deals wth value date prior or equal to the reporting date. We would like to include cashflows from contractual upcoming deals, from their trade date and before the actual value date. To raise funding, the bank issues debt securities and makes money market borrowing. As these deals are contractual, between the trade date and the value date we expect an inflow for the cash to be received as funding. Are we authorized to account these upcoming cashflows as inflows in the LCR? (between trade date and value date) And as soon as the value date occurs, the deal is booked as liabilities and it would become an outflow. The bank  makes money market lending. To be fair with the above approach, as these deals are contractual, between the trade date and the value date we expect an outflow for the cash to be delivered as a loan. Shall we  account these upcoming cashflows as outflows in the LCR? (between trade date and value date) And as soon as the value date occurs, the deal is booked as asset and it would become an inflow. If the above approach is approved by EBA, are we authorized to apply it only for Money market deals and issued securities? or shall we apply it for all deals? Our last concern is about the other reporting: If we apply this approach, shall we apply it as well to C66, NSFR? As it would make a deviation from the balance sheet in value date and especially the FINREP. Would it lead to EBA validation rules issues between the different reporting? Thank you,  

  • 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

Scope of Article 118 CRR - World Food Programme

Can the  Risk Weight of 0%  according to Article 118 CRR be applied on  the World Food Programme (“WFP”)?   According to Article 118(f) CRR exposures to an international financial institution established by two or more Member States which has the purpose to mobilise funding and provide financial assistance to the benefit of its members that are experiencing or threatened by severe financing problems, shall be assigned a risk weight of 0%. Can WFP be classified as an international financial institution in the meaning of Article 118 (f) CRR ? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Article 28 Outflows from other liabilities

Credit institution is not traditional credit institution - institution offers only loans and deposits. Client's have under their name Current account, but client's cannot operate those accounts. Client's can make payments to those accounts from other credit institutions and those accounts are used to pay out loans to client's account in other credit institutions. Does such current accounts should be reported for LCR calculation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

F 31.01 in combination with Q&A 915

According to Q&A_915 and EBA-ITS v3.0, the EBA considers validation rule 1034_m still as accurate. We're seeking a clarification whether EBA also has taken into account IAS 24.26 when answering in 2014.

  • 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

Calculation of the amount of holdings of own Common Equity Tier 1 instruments on the basis of the net long position

How should the condition in  Article 42 a) i)  “(i) the long and short positions are in the same underlying exposure and the short positions involve no counterparty risk”  be applied when there are long and short positions on the same underlying reference with the same counterparty under the same master netting agreement ?   Are the single net amounts fixed by such contracts to be considered rather than the gross amounts?  Explanatory note: The master netting agreement we are considering complies with the conditions required under CRR (Article 206)    

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Calculation of the amount of holdings of own Common Equity Tier 1 instruments on the basis of the net long position

Could it be assumed that short positions maintained with a Qualifying Central Counterparty do not involve counterparty risk according to Article 42 a) i) CRR and thus be netted for the purposes of the calculation of the amount of holdings of own Common Equity Tier I instruments to be deducted under point (f) of Article 36(1)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Calculation of goodwill included in the valuation of significant investments in insurance undertakings

A. For the purposes of a deduction under Article 36(1)(b) CRR as per Article 37(b), should the goodwill (Article 4(1) no. 113 and 115 CRR) included in the valuation of significant investments calculated excluding goodwill booked under an insurance subsidiary given that this goodwill is not included in the valuation of a significant investment of the bank (i.e. goodwill not included in the prudential consolidation as per Articles 1, 11, 18 and 24 of CRR and EBA RTS on the methods of prudential consolidation)?  B. Can you confirm that the goodwill booked under an insurance subsidiary (which is excluded from the valuation of significant investments as per prudential consolidation) should be treated as part of the equity exposure of the bank to the insurance subsidiary and this be risk weighted as per Article 49(1) and Articles 133 or 155 (depending on Standardized or Advanced IRB method)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Own credit risk

Should own credit risk be considered in the Alternative Standardised Approach of the FRTB?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C 33.00: Instructions concerning specific positions - c0020

Should column 0020 in C 33.00 be filled in as the sum of the columns 0030 to 0120 minus column 0130? Or should the net amount only be reported when the following condition is met: there’s a short position with the same immediate counterparty and residual maturity? If the current definition of column 0020 is considered correct, should validations v10651_m and v5853_h be changed?

  • 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

Scope of CRR definition of Financial Institution

Are deposits maintained by entities meeting the literal requirements of Article 4(1)(26) CRR excluded from the coverage of the Deposit Guarantee Schemes (DGS)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

EAD value for CVA calculation

Is the the EADiTotal in paragraph 1 gross of or net of incurred CVA. The definition provided by the regulation states that the effect of the collateral should be included but there is no reference as towards the incurred CVA regognised by the Bank as a write-down which under article 273 par.6 is applied in the calculation of the CCR RWA. "EAD total i = the total counterparty credit risk exposure value of counterparty ‘i’ (summed across its netting sets) including the effect of collateral in accordance with the methods set out in Sections 3 to 6 of Title II, Chapter 6 as applicable to the calculation of the own funds requirements for counterparty credit risk for that counterparty. An institution using one of the methods set out in Sections 3 and 4 of Title II, Chapter 6, may use as the fully adjusted exposure value in accordance with Article 223(5)."

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

LCR: Eligibility of HQLA held at EU subsidiary level for the consolidated HQLA liquidity buffer

Do credit institutions need to take into consideration as potential restrictions on the transferability of liquidity within the EU the (national) prudential rules that are not intended to restrict transferability of liquid assets but in practice may do so when assessing whether or not a liquid asset can be deemed readily accessible to a credit institution at consolidated level within the meaning of Article 8(2) LCR DR? For instance, do national statutory large exposures limits established by Member States pursuant to Article 493(3) CRR or statutory capital requirements at individual level more generally constitute such practical or legal impediment from consolidated perspective?

  • 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

Securitisation - application of look-through methodology

Should a bank follow the same approach for representing the exposure underlying a securitisation in Larex (large exposures reporting) as in COREP?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets

Validation rule v4821_m on column c0230 of Template C.08.02.

We wonder if there could be possible exceptions to the Validation rule v4821_m which always requires the LGD reported in column c0230 of Template C.08.02 by Obligor Grades to be always lower than or equal to 1.

  • 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)

v7386_m and v7387_m (COREP)

  We wonder about the consistency of validation rules v7386_m and v7387_m, which are set to verify that columns 0431 and 0432 of template C 14.01 should always be equal to or higher than columns 0900 and 0910 of Template C 13.01, respectively.

  • 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

Deduction of indirect holdings of own funds instruments in insurance and reinsurance undertakings which are subsidiaries of insurance holding company from own funds

Should indirect holdings of own funds instruments in insurance and reinsurance undertakings which are subsidiaries of insurance holding company be subject to the exemption provided for in Article 15a(2)(a) of Commission delegated regulation No 241/2014?   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions