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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

COREP C35 - consistency controls v09683_m; v09684_m and v09691_m

The control claims that for C35.01 row r0050 should sum row r0060 of C35.02 and row r0050 of C35.03. Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

Secured lending

Should mortgage loans be classified as secured lending in the LCR reports?

  • 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

Reporting of collateral posted / received in the C 66.00 maturity ladder template

What are the specific conditions for the treatment of collateral posted and received in relation to FX swaps and non-FX-related derivative transactions under the C 66.00 maturity ladder 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Pillar 3 disclosure on Net Stable Funding Ratio

How should NSFR LIQ2 table for Pillar 3 disclosure be compiled with respect to amounts reported in NSFR regulatory template C80 rows 0040, 0050 and 0060 for the non-HQLA part (i.e., 0010, 0020, 0030, respectively weighted by applicable weights reported in columns 0090, 0100, 0110). Those items seem to be not included in any of the weighted RSF items/components of LIQ2.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Incorrect Mapping Between Pillar III Template EU CR6-A and Corep Template C 08.07

Should the Mapping Tool for Template EU CR6-A (Annex to Regulation (EU) 2021/637) be amended in a way for Template EU CR 6-A r3,2 to match with COREP Template {C 08.01, r 0080} (SPECIALIZED LENDING SLOTTING APPROACH: TOTAL) instead of COREP Template {C 08.07, r0070}?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Large exposure treatment of structured derivatives, such as collar financing transactions (‘CFTs’)

For the purposes of large exposures (‘LE’), what is the appropriate treatment for structured derivatives (like covered calls, CFTs, etc.) in the application of the mandatory substitution (‘risk shifting’) rule in accordance with CRR Article 401(4) that requires an institution to treat the portion of the exposure collateralised by the market value of funded credit risk mitigation (‘CRM’) as exposure to the third party (collateral issuer) rather than to the client?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

What day count convention is to be used to determine level 2 securities in Regulation (EU) 61/2015 (CDR), Art. 11 (1) (e) (iii) and Art.12 (1) (b) (iii)

What day count convention is to be used to determine level 2 securities, in the case of corporate debt securities, that have to comply with a maximum time of maturity at the time of issuance of 10 years ( according to Regulation (EU) 61/2015 (CDR), Art. 11 (1) (e) (iii) and Art.12 (1) (b) (iii))?

  • 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

LCR treatment of letters of credit backed by deposits and letters of credit backed by committed lines

What is the LCR treatment of (i) letters of credit backed by deposits and (ii) letters of credit backed by committed lines?

  • 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

Determination of the total deposit balance of "all the client's deposit accounts"

Assuming a natural person has a bank account at a bank as a private individual. At the same time the individual is a (co)-owner of a legal entity, which qualifies as an SME, and the legal entity has a business account at the same bank. Shall the accounts of both the private individual and the legal entity be aggregated when checking the total deposit balance against the threshold of EUR 500,000? If so, how would the bank determine the appropriate share of the account balance of the legal entity (SME) if the individual is only a co-owner (e.g. 100%, 50%, etc.)?  

  • 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

Interaction between (i) CET1 deduction for minimum coverage on NPE and (ii) REA calculated under IRB-Advanced

In accordance with CRR art. 36(1)m and 47c the amount of insufficient coverage for non-performing exposures is to be deducted from CET1. Simultaneously the CRR requires institutions to calculate risk weighted exposure amounts (REA). This may result in a situation whereby for a given exposure the underlying risk is double-counted, once through available funds (deduction of CET1) and once through required funds (REA). Such double-counting is not intended, as also recognized in art. 67 of the ‘EBA REPORT ON STATUTORY PRUDENTIAL BACKSTOPS’. W.r.t. exposures under the IRB-Advanced approach the ‘EBA REPORT ON STATUTORY PRUDENTIAL BACKSTOPS’ further states in art. 69 that ‘In this respect Article 151(1) CRR clarifies that no own fund requirements should be imposed on parts of exposures that have already been deducted from CET1 while parts of exposures that have not yet been deducted from capital should still be risk-weighted to address any unexpected losses.’ While based on CRR art. 151(1) it appears clear that in theory only the exposure remaining after partial CET1 deduction (due to CRR art. 47c) is still to be risk weighted, clarification is sought on how exactly the risk weight on parts of a non-performing exposure is to be calculated in practice under the IRB-Advanced approach. Assume an exposure of 1000, under IRB-Advanced. Both the provision and the ELBE are equal to 300 (30%), while the LGD is equal to 500 (50%). In accordance with Art. 153(1) and 154(1) the REA is then calculated as 1000 * max(0, 12.5 * (LGD – ELBE)) or a REA of 2500. Now assume a minimum coverage expectation in line with art. 47c of 70%, i.e. 700. The resulting insufficient coverage thus equals 400, which is deducted from CET1. Remaining exposure to be risk weighted is 600. How to calculate the REA on this 600 given that ELBE and LGD were modelled based on an original exposure of 1000? Is our understanding correct that the REA on the remaining exposure is intended to be zero as provisions and CET1 deduction combined already exceed the (downturn) LGD? I.e. REA is only required for the 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

PD calibration sample

Given the definition of PD calibration provided in EBA/GL/2017/16 section 2.4 paragraph 8, and the requirements for the calibration sample provided in section 5.3.5, paragraph 88 of the same guidelines, for developing a TTC model, clarification is needed on the expectation on the implementation of the back-testing performed in the validation phase: Shall the back-testing at portfolio level verify that the average PD over historical observation period is aligned with LRA DR or, instead, shall the comparison be made between PD estimates current at the validation date and the LRA DR? Does it change according to the rating philosophy? Shall the back-testing always be performed on a 1-year validation sample, regardless the type of TTC calibration philosophy and regardless the length of the calibration sample? How shall the rating philosophy be taken into consideration when assessing the outcome of back-testing at grade level? Provided that the main aim of the calibration is to reflect the LRA DR, is the any case where the alignment to 1-year default rate should get a higher weight in validation assessment, although in a TTC calibration philosophy?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures

Is the RWA capped at EAD amount for IRBA exposures as suggested by SBP validation check v6210

SBP validation check v6210 is set as an error which prevents the reporting of exposures with RWA higher than 12,5xEAD.  Verification is sought to the legal rationale behind setting such a maximum RWA limit.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Exposure to an entity that holds a loan portfolio composed of purchased or self-originated loans which are secured by real estate properties and their assignment to the regulatory asset class “exposures associated with particularly high risk”

Does an exposure representing funding to an SPV that itself originates reverse mortgages loans with returns linked to the development of the relevant housing market and a business case involving a potential sale/securitisation of the underlying portfolio (see “Background on the question”) fulfil the requirements to be assigned to the regulatory asset class “exposures associated with particularly high risk” in accordance with Article 128(3) CRR and its specification as set out in EBA/GL/2019/01, even though the bank has contractual agreements with the SPV in place (i.e. covenants and LTV restrictions) which have a certain risk mitigating effect?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR

Exposure to an entity that holds a loan portfolio composed of purchased or self-originated loans which are secured by real estate properties and their assignment to the regulatory asset class “exposures associated with particularly high risk”

Does an exposure representing funding to an SPV, that itself purchases loans originated for speculative immovable financing purposes, fulfil the requirements to be assigned to the regulatory asset class 'exposures associated wth particularly high risk' in accordance with Article 128(3) CRR and its specification as set out in EBA/GL/2019/01, even though the bank has contractual agreements with the SPV in place (i.e. covenants and LTV restrictions), which have a certain risk mitigating effect?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR

Residential property

Artcile 4 (75) presents the definitions for Residential property - “residential property” means a residence which is occupied by the owner or the lessee of the residence, including the right to inhabit an apartment in housing cooperatives located in Sweden; Question ID: 2015_2304 has a aswwer:  "For the avoidance of doubt, the exposure has to be secured by a mortgage on residential property which “is or shall be occupied or let by the owner”. This excludes situations where residential property “may” be built in the future (i.e. mortgages on land) but includes mortgages on building sites on which residential property will be built for the future owner of the property, or on residential property under construction, provided in both cases that there is certainty that the owner will occupy or let the property. In this sense, the 35% risk weight cannot be applied to exposures towards real estate developers. This treatment does only apply to exposures fully and completely secured by mortgages on residential property, and not where units were to be exploited commercially. " If real estate company owns houses/apartments/flats and this company leases them to natural persons (for living) does these houses/apartments are consideres as residential properties or commercial properties in Your view? Clear Yes and No answer is needed.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C 27.00 - Identification of the counterparty (LE1) Report, column 040 -Residence of the counterparty

Reporting of the residence of the counterparty for a natural person. In order to report information on large exposures to natural persons the allocation in C27.00 Report column 040 -Residence of the counterparty should be done based on the country of residence or the country of nationality?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

Use of the substitution approach for retail exposures treated under IRB with a guarantee (unfunded credit protection)

The institution has exposures to retail clients (mortgage loans) that are treated under IRB. Some of these exposures have a guarantee (unfunded credit protection) that is eligible in accordance with the relevant requirements of credit risk mitigation. The institution applies Article 163 (4) and 164 (2) and adjusts PD or LGD estimates subject to requirements as specified in Article 183(1), (2) and (3) and the permission of the competent authorities. Does the institution has to use the substitution approach for this guarantee for large exposures (and thus present the counterparty giving the guarantee, and the guaranteed amount given as indirect exposure as financial guarantee under the large exposure reporting) as indicated in Article 403 (1)a?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Calculation of a Prudent Value in combination with CET1-Deduction according to article 89 and 90 CRR

In case of applying article 89 CRR in combination with article 90 CRR for a risk exposure (asset) is there a requirement of calculating an additional valuation adjustument (AVA) although the calculated amount of CET1-deduction of the risk exposure already lowers CET1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR

Debt securities issued by corporate treasury entities

Can debt securities issued by corporate treasuries organised in separate legal entities be classified as “corporate debt securities” for the purpose of Delegated Regulation (EU) 2015/61?

  • 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

DLT issuances that are sold exclusively to retail or corporate investors

In relation with Q&A 2013_288, can fully or partially tokenized issuances that are sold exclusively to retail or corporate investors, when duly proven and verified by DLT technology, be treated as retail stable funding or corporate funding (whichever applies) under the LCR and NSFR metrics ?  

  • 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