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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

Prior permission for repurchase of CET 1 instruments for discretionary trading activity over treasury shares for a certain predetermined amount.

Should the prior permission for the repurchase of CET 1 instruments for discretionary trading activity over treasury shares be subject to Article 78(1) last subparagraph of Regulation (EU) No 575/2013 (CRR)? In such case, would any general prior permission to repurchase CET 1 instruments for discretionary trading activity over treasury shares purposes result in a deduction from own funds at the time when the permission is granted or would a deduction from own funds be made at the time when the relevant repurchase of CET 1 instruments takes place?

  • 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
  • ID: 2017_3174
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 14/07/2017

Application of the definition of ‘speculative immovable property financing’ under the Standardised Approach

In case the borrower is the developer of a real estate project for which future contract agreements with future owners have been signed about the properties under development, would this exposure fall within the scope of the speculative immovable property financing?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3173
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/09/2018

Derivative adjustment of the basic annual contribution through mark-to-market method

For the purpose of Article 5(3) of Commission Delegated Regulation (EU) 2015/63 the valuation of derivative contracts should be done in accordance with the methodology specified in Article 429(6) and (7) of Regulation (EU) No 575/2013 (CRR) [as amended by Commission Delegated Regulation (EU) 2015/62]. How should this methodology be applied when adjusting the liability side, i.e. derivative contracts with a negative market value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3172
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 14/07/2017

Documentary credits in which underlying shipment acts as collateral and other self-liquidating transactions

Does a documentary credit secured by an assignment, assignment for security and/or pledge of the underlying sales contracts with payment to be effected to an account pledged in favour of either the lender (i.e. L/C issuing bank) or the security agent (especially in case of a syndicate) satisfy the condition of Annex 1 (3) (a) (i) CRR that “the underlying shipment acts as collateral or that the transaction is otherwise self-liquidating”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3171
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/10/2017

C 12.00 - v0519_m

According to the validation rule v0519_m, the following assertion should be evaluated for row r070 and all columns between c010 and c370. For each column, r070 = r080 + r090. We think this equality's rule cannot be applied to c0300 and c0320 columns which are used to report Average Risk weight in %. In fact, that calculating the weighted average of a whole is not equal to summing the weighted average of all its subpart.

  • 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: 2017_3165
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Deposits received and deposits posted as margin collateral for derivative exposures

Under Article 21 of Commission Delegated Regulation (EU) 2015/61: 1. Is the treatment of cash collateral received and cash collateral posted symmetrical in C73.00 and C74.00 in line with the answer given in Single Rulebook Q&A 2014_1089, which specifically referred to LCR C52.00 and C53.00? 2. Does the phrase “…collateral to be received” mean collateral already received at the reporting date?

  • 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: 2017_3163
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/11/2017

Validation rule on Leverage ratio templates - v4462_m

Should v4462_m validation rule be deactivated or changed?

  • 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: 2017_3159
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Validation rule v1384_m

With respect to remeasurement gains (losses) on defined benefit plans, IAS 19, par 120 (c) together with par 122 stipulate that these are to be reported as part of Other comprehensive income and shall not be reclassified to profit or loss. Par. 122 further allows that these remeasurement gains (losses) can be transferred within equity. Based on these rules, remeasurement gains (losses) on defined benefit plans are recorded as part of Other comprehensive income and as part of Retained earnings in our financial statements under IFRS. Hence these effects are reported in table 46.00 in row 200, column 060 as well as in table 03.00 in row 060 (pre-tax) and 090 (related taxes), column 010 in our Finrep submission.Validation rule v1384_m (F 46.00, r200, c050 + c100 = F 03.00 r360,c010) however doesn’t take up this entry made in table 46.00 for remeasurement gains (losses), which are recorded as part of Retained earnings, leading to a validation error.In our view, the validation rule should be amended to also consider template F 46.00, row 200, column 060, so that remeasurement gains (losses on defined benefit plans could be reported in the Finrep submission accordingly as allowed by IAS 19.

  • 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: 2017_3158
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Capital requirements for regular-way transactions during the settlement cycle

How shall regular-way transactions be treated during the settlement cycle, in particular where the settlement cycle is shorter than for long settlement transactions? Is the treatment of such pending settlement transactions different for trade date accounting vs. settlement date accounting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3155
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Use of Initial Margin (IM) posted by a Client as risk-mitigating effect in the calculation of the own funds requirement for CCP transactions the Clearing Member bank has with that Client

If a clearing member collects Initial Margin (IM) for client cleared trades and his collateral is passed to a QCCP, may the Clearing member recognise this collateral (IM) as risk-mitigating for calculation the fully adjusted value of the exposure (E*) according to CRR Art 223.5; independently of the method used to calculate the exposure ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3153
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Annex IV, template C 105.01, c060, interpretation of term "case weighted" in column 060 (Case Weighted average default rate for calibration)

We are seeking for a clarification regarding the term "case weighted" in column 060 - Case Weighted average default rate for calibration. Is the requirement to weight default rates by default occurrences in each year (1st interpretation) or to weight default rates by non-default obligor observations at the start of each year?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on reporting and disclosure requirements for investment firms
  • ID: 2017_3150
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

FINREP Taxonomy 2.7 Treatment of ECLs on FVOCI Assets

ECLs on FVOCI assets are recognised in equity, as per IFRS 9.5.5.2. How should these be treated on FINREP template 4.3.1?

  • 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)
  • ID: 2017_3146
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Hedging derivatives

Should reporting of derivatives on the asset side (F 20.04) be in line with the instructions of EBA on the liabilities side (F 20.06) and include both trading and hedging derivatives?

  • 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: 2017_3144
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Calculation of the maximum risk weighted exposure amount (RWEA) for securitisation positions in accordance with Article 260 CRR [prior to Regulation 2017/2401]

How shall specific credit risk adjustments made on securitised defaulted exposures treated in accordance with Article 110 CRR be recognised in the calculation of the maximum RWEA in accordance with Article 260 CRR [prior to Regulation 2017/2401]?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3143
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Is portfolio name a result of the portfolio allocation or a pattern column with addition rule semantics?

The excel workbook C 101.00 and C 102.00 in Annex I contains rules with pattern columns (like geographical area or regulatory approach) and result columns (like portfolio ID or counterparty code). What is about portfolio name? Is it a result column of the portfolio allocation, or a pattern column with addition rule semantics?

  • 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: 2017_3142
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Recognition of specific credit risk adjustments on securitised defaulted exposures under Article 266(1) CRR to reduce risk-weighted exposure amounts (RWEA) on IRB securitisation positions with 1250% risk weight (RW).

Shall specific credit risk adjustments made on securitised defaulted exposures and treated in accordance with Article 110 CRR be recognised to reduce RWEA on securitisation positions with 1250% RW in application of Article 266(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3141
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Use ‘AND’ or ‘OR’ rule to identify the exposure of the individual counterparties?

Template C 101.00 ‘Definition of Low Default Portfolio Counterparties’ (Annex I): Shall the columns Legal entity identifier, Credit register code, Commercial register code, ISIN Code and Bloomberg ticker be used with ‘AND’ or ‘OR’ rule to identify the exposure of the individual counterparties?

  • 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: 2017_3140
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Traitement des dettes subordonnées dans l'état C 68.00 et C 67.00 (Treatment of subordinated debt in templates C 68.00 and C 67.00)

Original questionPouvez-vous nous préciser le traitement à suivre concernant les dettes subordonnées dans l’état C 68.00 (financement par produit)? Translated questionCould you please clarify the applicable treatment for subordinated debt in template C 68.00 (Concentration of funding by product type)?

  • 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: 2017_3139
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/03/2018

Clarification of the treatment of contracts for difference (CFD)

Shall long (short) positions in CFDs, where the underlying is denominated in foreign currency, be treated as a single long (short) foreign currency position equal to the market value of the notional position of the underlying or market value of the CFD in the quote currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3137
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 29/11/2019