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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

Minority interest, AT1 and T2 instruments qualifying for inclusion in consolidated own funds

How should the calculation in Article 85(1) CRR be performed “on a sub-consolidated basis for each subsidiary” as required by Article 85(2) CRR, where no sub-consolidation or sub-consolidated own funds requirements apply to an institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3567
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 08/11/2019

Consistency of COREP validations rules e4896_n & e4895_n

Are the COREP EBA validation rules e4896_n & e4895_n consistent with Article 134 (7) of 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2017_3561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Reference date for determination of previous day’s values

To which day do Art. 364 1) a) i), Art. 364 1) b) i) and Art. 364 2) b) i) CRR refer to? To which days do Art. 364 1) a) ii) CRR, Art. 364 1) b) ii) and Art. 364 2) b) ii) of the CRR refer to?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Reference to Article 49 in Article 63(1)(k)

Is the reference to Article 49 in Article 63(1)(k) only related to the close out and termination of derivatives? Is the power to close out and terminate financial contracts valid for the purposes of applying all the Directive and not only Article 49?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3558
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Difference between a reduction to zero and a cancelation

Can you explain what is the difference between a reduction to zero and a cancelation referred to in Article 63(1)(e), (g) and (h) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3557
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Powers of resolution authorities Article 63 and Article 38(1)(a)

Both Article 63 and Article 38(1)(a) of Directive 2014/59/EU (BRRD) make reference to powers of resolution authorities. How do these powers complement one another?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3556
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

The EAD to be reported if no IRB exposure exists

Within the general instructions of Annex IV it is explicitly mentioned that for portfolios, which are defined with a specific rating grade in Annex I, information on the PD shall be reported for the entire rating scale, even if no IRB exposure exists for the respective portfolio at the reporting reference date for each rating grade. In this case, the EAD shall be reported as zero and information on the other columns shall not be submitted.The definition of the EAD in template C 101.00 states in turn that the exposure value shall be left blank if the institution has no IRB exposure for a given counterparty. In our opinion these two specifications are contradictory. Please clarify, if the exposure should be left blank or should be reported as “0” if no IRB exposure exists for the given counterparty/portfolio.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2017_3555
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

10 % LGD floor for retail exposures secured by residential property

How should an institution, which uses the IRB approach calculate the 10 % LGD floor mentioned in Article 164(4) CRR in the case where a part of the individual exposures are guaranteed by a guarantor (institution) which is treated under the Standardised Approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3554
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/08/2020

Reporting the gross carrying amount of the credit-impaired financial assets measured at amortised cost (other than purchased or originated credit-impaired financial assets), in the context of the new FINREP framework, as provided for in the Regulation (EU) 2017/1443

Our question is whether the gross carrying amount of a credit-impaired financial asset measured at amortised cost (other than purchased or originated credit-impaired financial assets) reported in the column 040 of the template F 04.04.1 “Financial assets at amortised cost” should be: a) the principal amount together with the value of the interest computed in accordance with IFRS 9 5.4.1(b) (not the entire value of the contractual interest accrued). or b) the contractual amount of the principal and of the interest accrued according to the contractual terms; in this case, the value of the accumulated impairment for this financial asset presented in the template F 04.04.1 would include the adjustment of the contractual interest (to attain the value of the interest revenue computed in accordance with IFRS 9 5.4.1(b)).

  • 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_3553
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Validation rule e4898_n

Is the validation rule e4898_n of ITS consistent with the Article 134(7) of 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: 2017_3548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/09/2019

Deduction requirements in accordance with Article 36(1) (f), (h) and (i) CRR: Netting of long and short positions in intermediate entities in the context of Article 15e (7) of Delegated Regulation (EU) No 241/2014 (“RTS Own Funds”)

Can an institution, in applying Article 15e (7) of Delegated Regulation (EU) No 241/2014 for the purpose of fulfilling the deduction requirements in accordance with Article 36(1) (f), (h) and (i) CRR – provided that all the conditions of Article 42 CRR are met - net long positions in an intermediate entity (such as an ETF) with corresponding short positions? 

  • 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_3543
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Value assigned to liabilities arising from derivative contracts

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: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2017_3542
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 15/12/2017

CIU Correlation Test

When applying the correlation test outlined in Article 350(2b) to a given CIU position in order to determine the appropriate capital treatment for position risk, may an institution adjust the historical prices of the CIU to reflect solely those price movements which relate to the position risk of that CIU?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3538
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Covered Bond issuance on template F35 Asset Encumbrance

Should retained bond nominals be included F35 of consolidated returns?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2017_3531
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Cash collateral posted in the Asset Encumbrance return F32.01

Where should cash collateral posted be treated in the Asset Encumbrance return F32.01?

  • 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_3530
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Validation Rules v5014_m and v5015_m for FinRep nGAAP (v2.6)

The definition of EBA Validation rules v5014_m and v5015_m does not work for FinRep nGAAP because template F 04.06 is missing in the formulas. 

  • 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_3527
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

C 17.01 – Total gross losses and loss adjustments (v6127_h and v6128_h)

In the new version of the ITS available on the EBA website which explains the functional requirements regarding the DPM 2.7, it's stated in the presentation of rows 010-880: ‘Institutions that calculate their own funds requirement according to BIA can report those losses for which the business line is not identified in rows 910-980 only.’In the definition of row 910, the ITS clearly states: ‘It may be higher, if an institution calculating its own funds requirements according to BIA cannot identify the business line(s) affected by the loss in every case. [...]'.This definition make sense for us, as it pastes with the requirement defined above mentioning that BIA losses may in certain cases only affect rows 910-980.But in the same case the definition of row 920-924 and the validation rules v6127_h and v6128_h seem to indicate that row 920 and 940 must be calculated as simple aggregation of the previous rows: ‘the gross loss amount (new events) reported in row 920 is the simple aggregation of the gross loss amounts of new events for each business line.’ Such indications for us are not consistent with the previous one indicating that for BIA only the total section may be fed.Please can you tell us in case of losses calculated under BIA with no business line attached how we should feed them in the C 17.01?

  • 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_3522
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 24/11/2017

CET1 Instruments

May a CET1 instrument rank pari passu in liquidation with a legacy Tier 1 instrument that is being grandfathered as Additional Tier 1 under Article 484, and otherwise qualifies as Tier 2 under the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3521
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Exposures to regional governments, local authorities or public sector entities which are treated as exposures to central governments under Articles 115 and 116 CRR

Please clarify how Article 115(2) CRR shall be applied in case regional governments and local authorities are treated under the SA by application of Article 150 CRR and central governments are treated under the IRB Approach. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3517
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Inconsistency in validation rule v5016_s for C 05.01

Is validation rule v5016_s consistent for rows 130 and 136 of the C 05.01?

  • 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_3516
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017