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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

Reporting C67 - "Concentration of funding by counterparty ", why the product coding has not evolved compared to the new EBA text ?

As part of the implementation of the new ITS on reporting on the ‘Additional Monitoring Tools’ to put into production by the end of March 2018, we found that in the specifications of new taxonomies for reporting C 67.00 – ‘Concentration of funding by counterparty’, the product coding has not evolved. The new EBA text mentions the renaming of the ‘REPO’ product category to ‘SFT’ and the addition of two new categories: ‘OSWF - Other secured wholesale funding’ and ‘OFP - Other funding products’.Why is the taxonomy not aligned with the new EBA text? 

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2018_3653
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Available financial means

Are all the financial means referred in Article 10 of DGSD available to finance measures to preserve the access of depositors to covered deposits according to Article 11.6 of DGSD?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3652
  • Topic: Funding provisions (financing means, use of funds, borrowing, calculation of contributions)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Scope of conversion factor estimation and application

Are positions with drawn amount without an underlying credit line (i.e. overdraft without credit line) within the scope of credit conversion factor estimation as per Article 166(8) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3650
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Credit Risk on Gold Bullion

Under Article 134(4) CRR, what would the risk weight be if gold bullion is held on our behalf by other institutions and where such investment is not backed by gold bullion liabilities?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3649
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/12/2018

Definition of “Paid-Up” according to Article 28(1)(b) CRR

May contributions in kind be qualified as “payment” according to Article 28 para 1 lit b CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3636
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Value for column c040 of template C 101.00 in case of counterparties with multiple ratings

How shall cells in column c040 in template C 101.00 be filled out in case of counterparties with multiple ratings?

  • 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_3635
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Write down or convert bail-inable liabilities following Article 48(3)

How would the resolution authority write down or convert bail-inable liabilities referred to in point (e) of Article 48(1) of Directive 2014/59/EU (BRRD) without previously reducing or converting the other instruments, regardless of the terms mentioned in points (a) and (b) of Article 48(3)?How should "substantially" in Article 48(5) be interpreted exactly?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3630
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 19/01/2018

Reference to value in Article 48(2)

Does the reference to “value” in Article 48(2) refer to the “face value” (“notional amount”) or to the “market value”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3629
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 26/01/2018

Clarification on application of incurred CVA to the Leverage Ratio Exposure calculation

Can incurred CVA, which is recognised as an incurred write-down in the Balance sheet, be used in the calculation of the Leverage Ratio Exposure for derivatives contracts?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2017_3628
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 15/11/2019

DPM 2.7.0.1 has not been fully aligned with 2017/2114

There shouldn't be inconsistencies between total and significant currency templates regarding general metrics - the only difference should be that significant currency templates should include (CUS:CU) [Currency with significant liabilities] and (CCA:CA) [Currency conversion approach metrics].Currently there are the following inconsistencies:C 66.01.w/ C 66.01.x/ C 66.01.y is missing (CCA:CA) [Currency conversion approach] - (CA:x1) [Expressed in currency of denomination (not converted to reporting currency)] metricC 66.01.a vs C 66.01.w are inconsistent on (CAL:AP) [Calculation method] and (MCY:MC) [Main category] for certain rowsC 66.01.b vs C66.01.x are inconsistent on (LIQ:LQ) [General liquidity requirements], (CPC:CT) [Counterparty sector of the collateral] and (MCY:MC) [Main category] on certain rowsC 70.00.a vs C 70.00.w are inconsistent on (MCY:MC) [Main category] on all rowsC 70.00.a row 1080 is inconsistent with the rest of the report on (MCY:MC) [Main category] metric(ei359) Product type (funding) [ei:MC:MC26] is missing two possible values required by ITS - OSWF and OFP 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3627
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Reporting of impact of adoption of IFRS 9 in F 12.01

How shall the impact of the adoption of IFRS 9 be reported in template F 12.01 “Movements in allowances and provisions for credit losses”?

  • 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_3624
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/04/2018

Inconsistency in validation rules v4748_m, v4749_m and v4750_m

In taxonomy 2.7, validation rules v4748_m, v4749_m and v4750_m are introduced for template C 07.00.Validation rule v4748_m expects the ‘fully adjusted exposure value (E*)’ (c150) to be equal to the sum of ‘Breakdown of the fully adjusted exposure value of off-balance sheet items by conversion factors’ (i.e. sum of c160, c170, c180, c190) across rows 010-060, 080 and 140-280 for all sheetsSimilarly, validation rule v4749_m expects (c150) to be equal to the sum of c160, c170, c180, c190 across rows 290 and 310 for all sheets and validation rule v4750_m expects c150 to be equal to the sum of c160, c170, c180 and c190 across rows 300 and 320 for all sheets.Column 150 includes off balance as well as on balance items and columns 160, 170, 180 and 190 is break down only off balance items by conversion factors. Hence, equality in this validations may not hold true always. So, are these validations 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: 2017_3623
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Recognition for large exposure purposes of a guarantee granted by the central government on an equity exposure

Can an equity exposure guaranteed by a central government be exempted from the large exposure framework or can only debt instruments be exempted? In particular, would such guarantees be compliant with the eligibility requirement set in Article 213(1)(b) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3621
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 20/11/2020

Asset Encumbrance - Eligible collateral in a central bank

Should deposits at central banks be reported as central bank eligible assets?

  • 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_3619
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 13/12/2019

IFRS 9, validation rule v1386_m

Validation v1386_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. {F 43.00, r070, c050} + {F 43.00, r070, c055} = xsum({F 20.05.b, c030, (r010-030, sNNN)}) Template 43 shall include reconciliation between the carrying amount of the item ‘Provisions’ at the beginning and end of the period by the nature of the movements, except provisions measured under IFRS 9 that shall instead be reported in template 12. In template 20.5, ‘Provisions for commitments and guarantees given’ shall include provisions measured under IAS 37, the credit losses of financial guarantees treated as insurance contracts under IFRS 4, and the provisions on loan commitments and financial guarantees under the impairment requirements of IFRS 9 and provisions for commitments and guarantees under national GAAP based on BAD in accordance with paragraphs 11 of this Part. Therefore template 20.5 can have a higher amount as template 43 and the validation rule can't be fulfilled.

  • 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_3618
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Interpretation of the term “commercial immovable property” especially “other commercial premises” for the application of the preferential risk weights for the risk weight assets purposes according to the Article 126 of the CRR.

What is the definition of “other commercial premises” as commercial immovable property in Article 126 CRR for the purposes of application of preferential risk weights for the risk weight assets purposes, if all other conditions stipulated in the CRR are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3615
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Market risk benchmarking – specification of portfolio 20

The specification for portfolio 20 includes shorting EUR 1 million per single-name 5-year CDS on 10 companies including ‘Unilever’. Should Unilever NV or Unilever PLC be used?

  • 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_3614
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Market risk benchmarking – specification of portfolio 15

The specification for portfolio 15 includes shorting EUR 2 million per single-name 5-year CDS on Italy, UK, Germany, France and USA (total EUR 10 million notional). What coupon rate should used for each country?

  • 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_3613
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Market risk benchmarking – specification of portfolio 12

The specification for portfolio 12 given in Section 2.2 of Annex 5 sets the initial spot price as ‘Level of USD/EUR on 12 October 2017’. Should London or New York closing time be used?

  • 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_3612
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Market risk benchmarking – specification of portfolio 10

The specification for portfolio 10 includes forward contracts purchased at the EUR/USD ECB reference rate as of EOD Oct 12, 2017. Are the forward contracts purchased at spot rate or forward rate (including fwd points)?

  • 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_3611
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission: