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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.

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List of Q&A's

Large exposures – excluding exposures if fully deducted from own funds

Will Q&A 787 still apply when the amended large exposures rules in accordance with CRR2 are in force?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5116
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Scope of Article 118 CRR - World Food Programme

Can the  Risk Weight of 0%  according to Article 118 CRR be applied on  the World Food Programme (“WFP”)?   According to Article 118(f) CRR exposures to an international financial institution established by two or more Member States which has the purpose to mobilise funding and provide financial assistance to the benefit of its members that are experiencing or threatened by severe financing problems, shall be assigned a risk weight of 0%. Can WFP be classified as an international financial institution in the meaning of Article 118 (f) CRR ? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6414
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Article 28 Outflows from other liabilities

Credit institution is not traditional credit institution - institution offers only loans and deposits. Client's have under their name Current account, but client's cannot operate those accounts. Client's can make payments to those accounts from other credit institutions and those accounts are used to pay out loans to client's account in other credit institutions. Does such current accounts should be reported for LCR calculation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6413
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Scope of CRR definition of Financial Institution

Are deposits maintained by entities meeting the literal requirements of Article 4(1)(26) CRR excluded from the coverage of the Deposit Guarantee Schemes (DGS)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6405
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

LCR: Eligibility of HQLA held at EU subsidiary level for the consolidated HQLA liquidity buffer

Do credit institutions need to take into consideration as potential restrictions on the transferability of liquidity within the EU the (national) prudential rules that are not intended to restrict transferability of liquid assets but in practice may do so when assessing whether or not a liquid asset can be deemed readily accessible to a credit institution at consolidated level within the meaning of Article 8(2) LCR DR? For instance, do national statutory large exposures limits established by Member States pursuant to Article 493(3) CRR or statutory capital requirements at individual level more generally constitute such practical or legal impediment from consolidated perspective?

  • 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
  • ID: 2022_6402
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Mandatory substitution approach according to Articles 401(4) and 403 CRR for Lombard Facilities

Could you please clarify the applicability of Article 401(4) and 403(1)(a) for other funded credit protection such as life insurance policies pledged to the lending institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6396
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Risk weight for asset class of non-preferred senior debt

What risk weight should be applied to non-preferred senior (NPS) debt, under the standardised approach for credit risk? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6394
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Interpretation of K-DTF

1. Are those transactions executed on behalf of the clients in its own name, as per DTF definition, to be included under K-COH?  2. Furthermore, are transactions pertaining to assets included in K-AUM to be excluded from K-DTF?    

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6383
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Own estimation of conversion factors for off-balance sheet exposures for binding mortgage/loan offers

Is the own estimation of credit conversion factors considered relevant for binding mortgage/loan offers, with a maturity of less than one year?. Should the total amount of a binding mortgage/loan offer be considered as "currently undrawn amount of a commitment that could be drawn" or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6368
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

EBA/GL/2017/16 Interpretation

Conformity of the  implementation pursuant to Article 152 CRR to 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
  • ID: 2022_6361
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Credit protection by an insurer provided directly on the pool of receivables

Can credit protection by an insurer, if provided directly on the pool of receivables (and not on a position held by an investor or originator in a structured transaction, can this protection), under circumstances, be taken into account in determining whether the transaction is tranched?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/09 - Guidelineson the STS criteria for non-ABCP securitisation
  • ID: 2021_6293
  • Topic: Provisions applicable to all securitisations
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Treatment of multi-seller securitisations in CRR (Significant Risk Transfer)

It is not clear from the provisions of the CRR how to treat multi-originator securitisations regarding the existence of significant risk transfer.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6143
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Calculation of the insufficient coverage for NPEs and capital absorptions related to Pillar 1 requirements on the same exposure

Regarding the applicable amount of the insufficient coverage to be deducted from own funds as per Article 36 (1) (m) CRR, to be determined at exposure level according to Article 47c(1) (b) of Regulation (EU) 2019/630, should the credit institutions applying the IRB approach consider the Pillar 1 capital absorptions already computed for credit risk for the calculation, on the same exposure, of the applicable amount to be deducted from CET 1 as per above, precisely to avoid any double-counting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5739
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 31/05/2022

Composition of the first and second lines of defence

What are the units composing respectively the first line of defence and the second line of defence?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/05 - Guidelines on internal governance under CRD - repealing EBA/GL/2017/11
  • ID: 2021_5731
  • Topic: Internal governance
  • Date of submission:
  • Published as Rejected Q&A: 31/05/2022

Calculation of specific risk own funds requirement for hedges by credit derivatives under Article 346 (4) CRR

Would be applicable the 80% offset stated in article 346(4) for the calculation of the specific risk own funds requirement of a hedged bond by an standardised credit derivative traded in a recognised exchange in case the maturity of the credit derivative is equal or higher to the bond maturity due to the standarization of the derivative.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5517
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/05/2022

Group financing companies of non-financial company groups / definition of "financial sector entity" in Article 4 (1) (27) CRR

Do group financing companies belonging to non-financial company groups (e.g. in the industrial sector) qualify as a "financial sector entity" according to Article 4 (1) (27) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5122
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 31/05/2022

The combination of values that forms a primary key differs between Annex II and the DPM-model 2.9. and does not account for the reporting of several critical functions.

How should institutions report multiple critical functions for which the values in columns 0010, 0030, 0040 and 0050 are the same?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2020_5185
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 31/05/2022

language versions

In case of discrepancies between text of English version of EBA Guidelines on outsourcing arrangements and its other language versions published on EBA website, which version should prevail - English or local one?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/02 - Guidelines on outsourcing arrangements
  • ID: 2022_6344
  • Topic: Internal governance
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Documentation language - Do IRB documentation need to be in English?

Does IRB documentation need to be in English? Is there any official guideline on what documentation is acceptable in non-English language?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6340
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022