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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

Non Performing Loans at group levels.

Clarification is requested as to when group (connected) accounts should be downgraded to the Non Performing category (NPL) when only one party from within this group classifies as an NPL (refer to the 2nd part of para. 155). Should group facilities be downgraded: 1. When exposures past-due by more than 90 days represent 20% of the gross carrying amount of a singly debtor (one party within group entities) or 2. When exposures past-due by more than 90 days represent 20% of the gross carnying amount of the total group exposure? or is this left at the discretion of the credit institution? 

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1113
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Content of “accumulated changes in fair value due to credit risk” in template F 16.05

Column 020 of template F 16.05 is labeled as “Accumulated changes in fair value due to credit risk”, whereas the respective instructions (paragraph 100 of part 2 of Annex V of the ITS on supervisory reporting) reads “Institutions shall report the net realised and unrealised and the amount of change in fair value in the period due to changes in the credit risk (own credit risk of the borrower or issuer).”. We would like to get confirmation that the instructions shall be followed and that the use of the word “accumulated” in the second column of F 16.05 is a typo.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1109
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Loans collateralized by immovable property in F 05.00 and F 13.01

Do loans collateralized by immovable property in template F 05.00 contain only residential and commercial immovable property, like in F 13.01, or are they open to other collateralized immovable property (those which do not meet the definition of residential and commercial provided by CRR)? If the former, are those loans collateralized by other immovable property reported as other loans collateralized?

  • 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_1108
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Validation Rule v0629_m

Can rule v0629_m be valid in any case? Namely, in some cases (see background information) the own funds requirements for foreign exchange stipulate that the foreign exchange risk be calculated as the sum of its overall net foreign exchange position and its net gold position in the reporting currency, multiplied by 8 %, not by 12,5%, which is what the rules, in effect, validates.

  • 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_1107
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Non-performing exposures - Cash balances at central banks, Non-current assets held for sale

Does template F18.00 DEBT INSTRUMENTS AT AMORTISED COST (rows 010 to 180) include Cash and cash balances at central banks portfolio? Does template F18.00 DEBT INSTRUMENTS AT FAIR VALUE other than HFT (rows 190 to 320) include Non-current assets and disposal groups classified as held for sale?

  • 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_1106
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/11/2014

Groups including an investment firm referred to in Article 95(1) of the CRR controlled by a financial holding company or mixed financial holding company

How shall the own funds requirements be calculated for a group including an investment firm referred to in Article 95(1) controlled by a financial holding company or mixed financial holding company (and no credit institutions)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1105
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 01/08/2014

Significant risk transfer applicable to leverage ratio computation

Should the concept of significant risk transfer be applied to the leverage ratio computation of securitisations? Should the underlying exposures be taken into account in case of no significant risk transfer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1104
  • Topic: Leverage ratio
  • Date of submission:

Clarification regarding the legal opinion mentioned in Article 305 of Regulation (EU) No 575/2013 (CRR)

Is it correct to assume that the specific legal opinion mentioned as a prerequisite in Article 305(2)(c) CRR only needs to confirm that the other prerequisites 'individual client segregation' in Art 305(2)a) and the facilitation of the portability of client assets under Art 305(2)(b) are in place and fulfilled (in a sense that the respective legal position of the client is enforceable under respective law(s)), or does the legal opinion need to address additional legal questions beyond that scope? In the latter case what kind of legal questions beyond Art 305(2)(a) and (b) would such legal opinion need to address?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1102
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 01/08/2014

Validation Rule v2245_h

Should column 090 from form CR GB 2 still be in the scope of validation rule v2245_h? As the rule validates a sum and column 090 contains percentages it cannot be correct.

  • 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_1101
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

FINREP Template 13.2 and 13.3

The difference between the templates 13.2 and 13.3 and the purpose of template 13.3 is not clear. Can you please explain the following questions.1.)Template 13.2 “Collateral obtained by taking possession during the period [held at the reporting date]”: We have understood that “during the period” means Information about obtained Collateral year-to-date (ytd). That means from 1. January to Reference date. Is this correct?2.)Template 13.3 “Collateral obtained by taking possession [tangible assets] accumulated”: We have understood that “accumulated” means life-to-date (ltd). Is this correct?3.)The heading of Template 13.3 is “Collateral obtained by taking possession [tangible assets] accumulated”. In de ITS part 2.84 you explain, that this template excluding those classified as “Property, plant and equipment”. For our understanding the definition of tangible assets are the same definition of Property, plant and equipment. Is the heading incorrect? If not, can you please confirm the purpose of this Template.

  • 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_1094
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Validation Rules: v0219_m, v0221_m

Both rules validate the Surplus(+) / Deficit(-) of certain capital:- v0219_m for CET1 Capital- v0221_m for T1 CapitalThe question stands: Should the range of percentages from Article 465 CRR be implemented in the validation rules for each type of capital or should the fixed percentages in Article 92 CRR be upheld?

  • 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_1093
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Different ID

Why "Public sector entities" dimension in the table C 07.00 does not have same type of linking to the table C 02.00 as does have for example "Regional governments or local authorities" dimension?

  • 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_1090
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Deposits received as collateral

Under 423(6) of Regulation (EU) No 575/2013 (CRR) should the deposits received as collateral be calculated as net posted collateral in order to treat posted and held cash collateral symmetrically? What if more cash collateral is posted than held? Thus should all other posted level 1 collateral not be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1089
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/04/2015

Fiduciary loans and deposits

Considering that for FINREP reporting the fiduciary loans and deposits are explicitly excluded from Balance Sheet could you please advice whether the same treatment applies to COREP (including Large Exposures) reporting? That is, if fiduciary loans and deposits should be excluded from all COREP and Large Exposure reports.

  • 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_1088
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Specific credit risk adjustments

Which item in the CA1 report should be used for reporting "immediate reduction in Common Equity Tier 1 capital" as described under Article 1 paragraph 1 second subparagraph of the Commission Delegated Regulation (EU) No 183/2014, in order to reduce the amount of exposure for specific credit risk adjustments for the purposes of calculation of risk-weighted assets?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2014_1087
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/11/2015

Annex II and VIII of the ITS on supervisory reporting under the CRR

According to the Article 395 paragraph (5) point a) of CRR the limit to large exposure may be exceeded for the exposures on the institution's trading book – among others - if the exposures on the non-trading book do not exceed the limit laid down in paragraph (1). How shall the excess of limit to the large exposure on the non-trading book after CRM be reported in the CA2 template?

  • 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_1085
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Implementing Technical Standards (ITS) on additional liquidity monitoring metrics

Concerning the instructions for the counterbalancing capacity by issuer/counterparty (CCC). Can the same issuer/counterparty appear more than once in the top 10 in this CCC by issuer/counterparty report?

  • 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_1084
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Validation rule v3995_u

Please check the appropriateness of validation rule (v3995_u) "{C 27.00, c010} is a row identifier, and must be unique for each row in the table"

  • 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_1080
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Supervisory powers Liquidity

Does Article 412(5) of Regulation (EU) No. 575/2013 (CRR) prohibit the competent authorities from imposing a “Liquidity-Add-on” (e.g. LCR-requirement above 100%; similarly to a Capital-Add-on according to Article 104(2) of Directive 2013/36/EU (CRD) according to Article 104(1)(k) and/or Article 105?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1077
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 25/07/2014