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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

Reporting liabilities excluded from bail-in in templates M05, M06

The general remarks for both templates M05 and M06 state the following: Liabilities excluded from bail-in; these liabilities shall be included to the extent that they rank pari passu with or junior to any instrument included in the amount of eligible liabilities for the purposes of internal MREL (M05)/ MREL (M06). Does this mean that other liabilities excluded from bail-in, i.e. those ranking senior to eligible liabilities will not be included in any of the columns of templates M05 and M06? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/1450 - RTS specifying criteria for MREL (minimum requirements for liabilities eligible for bail-in)

Standardised Approach Original Exposure pre conversion factors

Should all assets deducted from own funds be reported under Original Exposure pre conversion factors (C07.00 - column 0010) and hence considered as Value adjustments and provisions associated with the original original exposure (C07.00 - column 0030)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Correlation EBA_v7336

Please, review the EBA_v7336 correlation.

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

Classification as a “specialised debt restructurer” pursuant to Article 36 (5) of Regulation No 575/2013

To be classified as "specialised debt restructurer" (SDR), the institution’s sight deposits must not exceed 5% of the institution’s total liabilities. Within the context of the regulation, what is the appropriate interpretation of sight deposits when assessing if they meet the conditions from Article 36 (5) (f) of the Regulation (EU) No 575/2013? 

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

Classification as a “specialised debt restructurer” pursuant to article 36 (5) of Regulation No 575/2013

For how long prior to an institution’s classification as a specialised debt restructurer must all the criteria specified in article 36 (5) of Regulation No 575/2013 be met by the institution?

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

Interaction of the risk drivers employed to define the structure of the PD model and the requirement to avoid the excessive cyclicality of own funds requirements.

Is considering the requirement of CRR Article 170 4(c) to incorporate the ‘delinquency’ risk driver in the structure of rating systems possible, to avoid a potential excessive cyclicality of own funds requirements via the use of appropriate calibration techniques in line with the Entity’s chosen 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

Interaction of the structure of the rating system and homogeneity requirements with conservatism in the application of risk parameters

Considering a rating structure defined according to article 170 of CRR, would the consideration of conservatism in the application of risk parameters alter such structure? In particular, do homogeneity analyses need to be conducted before or after the consideration of the conservatism in the application of risk parameters described in section 8.1 of the EBA/GL/2017/16?

  • 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

Treatment of lease commitments from operate-lease contracts in supervisory reportings

Gemäß Art. 5 Abs. 1 CRR sind Risikopositionen als Aktivposten (Vermögenswert) oder außerbilanzieller Posten definiert. Bedeutet dies im Umkehrschluss, dass Leasingzusagen für Operate-Lease-Verträge nicht in den aufsichtsrechtlichen CRR-Meldungen auszuweisen sind, da diese nach nationalen Bilanzierungsregeln (HGB) nicht als außerbilanzieller Posten unter dem Bilanzstrich auszuweisen sind? According to Article 5 (1) CRR, risk positions are defined as an asset or off-balance sheet item. Conversely, does this mean that lease commitments for operate-lease contracts are not to be shown in supervisory CRR reportings, as these are not to be reported as off-balance sheet items below the balance sheet line under national accounting rules (HGB)?

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

Failed rule EGDQ_0875 – proposed check on 12/2023 FP

How to cope with the issue described below for the future EBA Funding Plan deliveries avoiding any “failed” rule?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05

Funding plan - validation rule EBA_v08993

How can we solve a breach in the v08993_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities to be declared in P01.02 in line r145 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05

Funding plan - validation rule EBA_v08992

How can we solve a breach in the v08992_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities  to be declared in P01.02 in line r140 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05

Funding plan - validation rule EBA_v08991

How can we solve a breach in the v08991_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the deposits to be declared in P01.02 in line r130 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05

Funding plan validation rule EBA_v08990

How can we solve a breach in the v08990_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the deposits from non-financial corporations to be declared in P01.02 in line r060 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05

validation rule EBA_v08988

How can we solve a breach in the v08988_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the repurchase agreements  to be declared in P01.02 in line r010 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05

EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).

The “Custody assets” referred in FINREP 22.2 is described as “services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”.  How should the word “Services” in the above definition be interpreted?  Does it mean to populate a balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee that is charged or revenue being generated? Extract from Annex V 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and other services provided by the institution shall be reported using the following definitions:  (a) ‘Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management. ‘Asset management’ shall be reported by type of customer: collective investment undertakings, pension funds, customer portfolios managed on a discretionary basis, and other investment vehicles;  (b) ‘Custody assets’ shall refer to the services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management. ‘Custody assets’ shall be reported by type of customers for which the institution is holding the assets distinguishing between collective investment undertakings and others. The item ‘of which: entrusted to other entities’ shall refer to the amount of assets included in custody assets for which the institution has given the effective custody to other entities;   As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSII is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

  • 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 (repealed)

Supervisory delta for commodities with negative prices

Article 279a (1), (a) of the CRR establishes the formula to be used for calculating the supervisory delta of options mapped to all risk categories except for the interest rate category. Can such formula be made compatible with market conditions in which commodities may have negative prices?

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

Application of the formula for the determination of the risk weight for a specific vega risk factor k

Is it permitted to use the formula proposed in the original Basel text (MAR 21.92) to calculate the risk weight for a specific vega risk factor k, in deviation from Article 325ax Paragraph 3 CRR?

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

Fair value adjustments that arise as a result of applying fair value hedge accounting

This question is a reformulation of the Q&A 4406, with two examples for clarify the problem and some possible answers. Should fair value adjustments which arise as a result of applying fair value hedge accounting to mitigate interest rate risk be treated under the CRR credit risk framework or under a different risk framework? And if under a different risk framework, which risk framework should that be?

  • 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 (repealed)

Definition of financial institution under Article 4(1)(26)

Does the definition of financial institution under Article 4(1)(26) CRR include trust companies under Liechtenstein law?

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

Definition of ancillary services undertaking under Article 4(1)(18)

Does the definition of ancillary services undertaking under Article 4(1)(18) CRR include trust companies under Liechtenstein law?

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