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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

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)

Specialised lending for the ‘Low Default portfolios’ Supervisory Benchmarking Exercise 2017

According to the instructions related to the Supervisory Benchmarking Exercise 2017 for ‘Low Default portfolios’, we are supposed to report portfolios assigned to one of the following exposure classes:(a) Central governments and central banks(b) Institutions(c) Corporates – Other(d) Not applicableThe legal reference for this column is the Paragraph 78 of Annex 2 of Commission Implementing Regulation (EU) No 680/2014. This paragraph 78 defines clearly the different exposure classes and particularly distinguishes ‘Corporate – Other’ and ‘Corporate - Specialised lending’ according to article 147 of the regulation (EU) No 575/2013. Thus, we understand that the ‘Specialised lending’ is not to be reported for the ‘Low Default portfolios’ Supervisory Benchmarking Exercise 2017. Please confirm our understanding regarding ‘Specialised lending’.

  • 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)

Level of data to be reported for LEI codes provided in Annex I

For Template C 101.00, should we report position of the specific Low Default Counterparty mentioned in Annex I or also report position of the underlying organisations belonging to that Low Default Counterparty?

  • 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)

Data level for template C 101.00 of Annex III related to Exposure Classes (column 020)

We notice that the same customer can fall into multiple exposure classes. How should we report such customer which has multiple exposure classes? Would it fall in one row with exposure class of the largest exposure or split exposure per exposure class in multiple rows?Example:There are customers in our dataset that could fall into 2 exposure classes being Corporate – Specialised Lending and Corporate – Other.How to treat such customers?

  • 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)

Template C 105.01 for 2017 exercise (end 2016 data)

According to the 2017 exercise related to “Low Default Portfolios”, entities shall submit Template C 105.01. Given the specific characteristics of these portfolios (low default), information regarding to “default rate”, “cure rate”, etc. is not used in the estimation. Therefore, estimation is based on external information. Overall, are these fields mandatory to report in Template C 105.01? And if so, which ratios should be included?

  • 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)

RWA Standardised (c180 of C 102.00 and C 103.00)

According to Article 7 of Commission Implementing Regulation (EU) 2016/2070 of 14 September 2016: “As a derogation from Article 2 and until 31 December 2016 an institution shall not be required to report c180 of templates 102 and 103 of Annex III where that institution does not compute the own funds requirements for credit risk resulting from the application of the standardised approach”. Are RWA Standardised exempted from the reporting by 11 April 2017 in Template C 102.00, given that information is referred to 31 December 2016?

  • 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)

Report of Type of Facility

Definition of Low Default Portfolios in C 102.00 requires classifying portfolios by Type of Facility. In order to do this we evaluate two main options.The first one consists of assigning each value of Type of Facility in accordance with the global product, so an entire contract will be classified into a unique value of that field.The second one consists of assigning on-balance amount of a contract as “Drawn” and the off-balance amount in any of the 6 remaining options for “Undrawn facilities”.What is the more adequate way to operate?

  • 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)

Treatment of central bank reserves in third countries

What is the treatment of central bank reserves in third countries held by a branch?Does the eligibility of those reserves for the purpose of the LCR strictly depend on the existence of an agreement between the competent authority of the reporting institution and the central bank in which the conditions of a withdrawal have been specified?

  • 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

Reference to point (b) in Article 60(2)

The final sentence in Article 60(2) refers to point (b). Is that reference correct or is it meant to refer to point (c) of the same Article?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Rating grades in Annex I of the draft ITS on benchmarking

Please confirm the approach to be applied regarding the master scale.According to us, two options seem possible:Case 1: use only the necessary number of proposed available rating grades of the annex 1 (e.g. in case we have 30 different non defaulted values in our master scale, we would map them with the 30 first rating grades of the annex 1)Case 2: distribute the internal master scale on the whole range of the proposed rating grades of annex 1 (e.g. in case of 30 different non defaulted values in our internal master scale, "internal_rating_1" = "rating 1", "internal_rating_2" = "rating 4", "internal_rating_3" = "rating 7", ... , "internal_rating_30" = "rating 99").This should allow a more homogeneous distribution of the different master scales of the institutions in the regulatory proposed master scale from "rating 1" to "rating 99".

  • 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)

IMV definition for 2017 Market Risk Benchmarking exercise

In Annex V.b it is stated that the Initial Market Value (IMV) means the 'unrealized balance'. Institutions seek more guidance in how to apply this. Should it be the mark-to-market on 27 October 2016, or the difference between the MtM's of 27 October 2016 and 13 October 2016?

  • 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)

Model selection/use in context of a pending application of a significant model change

Should an institution that expects to receive approval to use a new internal market risk model following the remittance of IMVs but prior to the remittance of the risk measures submit IMVs using the old model or new?

  • 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)

Annex V, Section 2.4: Market Benchmarking Portfolios. Definition of Portfolio 16 (FX)

Please confirm that the NYC Closing on 13 October 2016 should be used for the determination of the barrier.

  • 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)

Annex V, Section 1: Market Benchmarking Portfolios. Definition of Portfolio 13 (FX)

For consistency we will also use the EUR/USD ECB reference rate for the option in portfolio 13. Please confirm that this is appropriate.

  • 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)

Annex V, Section 1: Market Benchmarking Portfolios. Definition of Portfolio 10 (IR)

We will use 16 October 2018 as start date for the swap and thus 14 October 2018 as maturity of the option. Please confirm that these dates are appropriate.

  • 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)

Clarification on portfolio specification.

The Common Instructions paragraph (n) mentions that the commodities OTC options are American. However, American style WTI options are listed options not OTC. Should we therefore book a European option with a maturity date of 13-Oct-2017 ?

  • 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)

Clarification on portfolio specification.

For Portfolio 1.27 the maturity of the index option is given as 15-Apr-2017 (a Saturday). Index options expire on the 3rd Wednesday of the month. Should the maturity be 19-Apr-2017 ?

  • 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)

Clarification on credit portfolio specifications.

Portfolios 1.35, 1.36, 1.37: For CTPs page 16, we are being asked to book the hedges such that net CS01 is 0 as of initial valuation date. From point (b) page 2 it seems that initial valuation date is 27-Oct-2016. This will mean that the hedges can only be booked on the 28-Oct-2016. However point (a) in page 2 specifies that “all positions shall be booked 13 October 2016”. Can you clarify what is the correct approach ?

  • 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)

Benchmarking portfolios: termination date

Annex V portfolio 1.28 Scheduled termination date 18 December 2021 is a non-working day (Saturday). Should the termination date be 17 December 2021?

  • 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)