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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

Validation rule v23688_s requiring only non-negative amounts appears incorrect

Is validation rule v23688_s incorrect? 

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

C06.02 - v23688_s - Non negative control

The control indicates that the following columns have to be positive :   c0360 = consolidated own funds   c0370 = of which : common equity Tier 1   c0390 = oh which: contribution to consolidated result Should this control be applicable?

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

C07.00 - v23338_m - RW of 70% empty

The EBA Validation Rule v23338_m applicable to C07.00 COREP template states that the line 210 that concerns the RW of 70% must be empty. Should this control should be applicable?

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

C17.01 - v23507_h - Sum of number events by Basel Business Line

Is the aggregation logic assumed by the control v23507_h is not applicable in this context.

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

C17.01 - v23508_h - Sum of number of events by Basel Business Line

Is the aggregation logic assumed by the control v23508_h applicable in this context?

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

v23509_h and v23510_h

Are the validation rules v23509_h and v23510_h correct when reading the reporting instruction of the ITS. In our view the reporting instruction of the ITS is not clear enough.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules v23509_h and v23510_h appear incorrect

Are validation rules v23509_h and v23510_h correct?

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

C_ 08.01.a - qx 2068 – “Retail exposures - Secured by residential real estate”

Should the retail exposures secured by residential real estate to a natural person and the retail exposures secured by residential real estate to an SME both be assigned to the exposure class of “Retail exposures secured by residential real estate” in C_08.01.a qx 2068?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules taxonomy V4.0 C_17.01

Validation rule v23510_h incorrect

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Presentation of lending for house purchase

Can loans that are directly disbursed to customers be considered as lending for house purchase?

  • 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)

The instructions for row 0170 C10.00 seem inconsistent.

The instructions for row 0170 C10.00 seem inconsistent. The title of the line item "Of which: categorised as secured by residential real estate in IRB" refers to secured by residential real estate. Whereas further instructions, "Exposures assigned under IRB approach to the exposure class 'Purchased receivables' pursuant to Article 147(2), point (d)(ii) of Regulation (EU) No 575/2013.", refers to Purchased recaivables. The article mentioned, 147(2)(d)(ii), refers to retail exposures secured by residential property.  Is our understanding correct that this row should not only be populated for Purchased receivables under the IRB approach but actually should be populated for secured by residential real estate under IRB approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

FINREP – Loan commitments, financial guarantees and other commitments given

In the context of FINREP template F 09.01, could the EBA clarify whether the scope of columns 0100 and 0110 is intended to include exposures (commitments and certain contractual arrangements that are not commitments as referred to in CRR Article 5/110a/111(4)) that fall under CRR3 Annex I but are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37?

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

COREP Template 236. Specialised Lending Supervisory Slotting Method

How should institutions reflect, in COREP template C 08.01, credit risk mitigation (CRM) techniques applied to exposures subject to the slotting approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

ASF factor for AT1 and T2 capital instruments with residual maturity of a minimum of six months but less than one year

For the purposes of calculating available stable funding, what ASF factor shall be used for capital instruments with residual maturity of a minimum of six months but less than one year?

  • 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)

Reporting of retained own issuances in the ALMM C 66.01 maturity ladder template

How should credit institutions report, at consolidated level, in the ALMM C 66.01 maturity ladder template, retained own issuances that do not appear on the consolidated balance sheet?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Finrep validation between F09.01.1 and F18.00 other commitments given

If we have undrawn credit facilities that based on CRR Annex I are reported under Other commitments given in F18.00 r0480 c0010, but they do not meet any of the conditions described in Annex V Part 2.105 (a-c) to be reported in F09.01.1, we cannot report them on F09.01.1 but in F18.00 only.  Validation errors  v2795_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0480, c0010} = {F 09.01, r0170, c0010} + xsum({F 09.01.1, (r0170, c0010, c0020, c0030, c0035, c0100)}) and v2797_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0500, c0010} = {F 09.01, r0200, c0010} + xsum({F 09.01.1, (r0200, c0010, c0020, c0030, c0035, c0100)})  require that Other commitments given match in both these tables. What if the conditions mentioned in Annex V Part2.105 are not met for the other commitments given in F18.00?

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

Recognition of FX hedging on loan collateral value for volatility adjustments for currency mismatch

In case of a loan secured by financial collateral where the currency of the loan differs from the currency of the collateral, the FX risk is hedged by a financial instrument (cross-currency swap) which proceeds are pledged by the obligor to the lending institution. Such cross-currency swap hedge allows the lending institution to offset any loan collateral value decrease due to a depreciation of the collateral’s currency, thus neutralising any effect from the currency mismatch between the currency of the loan and the currency of the collateral. In this case, is it possible to assimilate for the purpose of article 223(1) of CRR that the collateral is denominated in the same currency as the loan (implying that no volatility adjustments for currency mismatch would apply) ?

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

Use of ECAIs' ratings for risk-weighting purposes under Regulation (EU) No. 575/2013, as last modified by Regulation (EU) 2024/1623 of the European Parliament and of the Council of 31 May 2024 ("CRR")

The question is concerned with the following specific case: in connection with a specific private financing, a credit institution requests a rating for a certain entity which is among the credit institution’s customers and:  the rating is issued by an ECAI (as defined under art. 4(1)(98) CRR); the relevant ECAI is covered by the EBA's Mapping of ECAIs’ credit assessments under art. 136 CRR; the rating, being not requested by (or on behalf of) the rated entity/issuer and/or a related third party and is classified "unsolicited" and EBA's Decision 2021/397 (confirming that unsolicited credit assessments of certain ECAIs do not differ in quality from their solicited credit assessments under art 138 CRR - EBA/DC/2021/397) applies to the relevant ECAI; the rating follows the same published methodologies – and is based on the same set of information – as public ratings and this is expressly confirmed by the relevant ECAI; the rating, although private, is not subject to any contractual restrictions preventing the ECAI from issuing the same rating to third parties or, where applicable, on publication or distribution; namely, the ECAI, ceteris paribus, can issue the same rating to any other credit institution upon request, ensuring that the output is made available to all requesting entities on an equal basis.  Within this context, we seek confirmation that the unsolicited and private rating issued by the ECAI, in the case under consideration, can be used by the credit institution under the CRR for attributing risk weights in the standardized approach.

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

Netting of income and expenses and mutualisation of losses for IPS in the Service Component of the Business Indicator (BI)

To which items of the Services Component, the net of “any income received from, or expenses paid to” of the second paragraph of Art. 314(5) refers to? It is unclear whether it refers to all the items of the Services Component, to the income and expenses of the “Fee & Commission” or to the income and expenses of the “Other Operating” as defined in Art. 314(5) first paragraph.  The last sentence of Art. 314(5) provides the following: “Any losses resulting from the related operational risks are subject to mutualisation across institutional protection scheme members.” Is it a requirement for the use of the netting exemption? Can institutions that are members of an institutional protection scheme meeting the requirements of Article 113(7) apply the netting or can such institutions apply the netting only if there is a mutualisation by the Institutional Protection Scheme (IPS)? Is this mutualisation referring to threatening operational risk losses only or to any losses resulting from the related operational risk events? 

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

Validation rules taxonomy V4.0 C07.00

The EBA Validation rules taxonomy v23005_m seems not relevant

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions