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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

EBA validation rule v2853

EBA validation rule v2853 requires OTC derivatives in template AE-SOU (F32.04; r0030,c0010) not to be higher than OTC derivatives in FINREP (sum({F 10.00, c0020, (r0300-0320)}) + sum({F 11.01, c0020, (r0510-0530)}) + sum({F 11.02, c0007, (r0240-0260). However in FINREP the net carrying amount should be reported as in the AE-SOU template the gross carrying amount should be reported. The gross carrying amount before accounting netting can be higher than the net carrying amount. Is this validation rule still correct?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Determination of exposure value cap for netting sets subject to a margin agreement.

The final answer to EBA Q&A 2023_6962 states that when capping the exposure value of a margined netting set at the exposure value of the same netting set not subject to any form of margin agreement “The term NICA, included in the formula set out in Article 275(1) and defined in Article 272(12a), does not include the variation margin posted or received.”   We believe that this is an incorrect reading and could lead to significant under estimation of RWAs whenever the institution is posting significant excess collateral to its client. This can happen particularly when trades with a large MTM unwind at maturity and the collateral balance is exchange back only on T+1 basis.   Take the following example scenario. If calculating the EAD per the margined methodology the variation margin posted to the client offsets some of the MTM of the derivatives and the add-on is fully added to EAD as the multiplier remains 1.    However under the unmargined methodology if I disregard the posted collateral then the negative current replacement cost works to significantly offset the add-on and can actually result in an EAD below the EAD incurred on only the actual replacement cost/current exposure (in this example 140).   Example Scenario       MTM of Derivatives -50 Variation Margin posted to client 150 Replacement Cost (Margined) 100 Add-on (pre multiplier) 100 Multiplier 1 EAD per margined methodology 280     MTM of Derivatives -50 Variation Margin posted to client (ignored as not NICA) 0 Replacement Cost (Unmargined ignoring VM posted) 0 Add-on (pre multiplier) 100 Multiplier 0.78 EAD per unmargined methodology 109     Final capped EAD to unmargined 109   Our understanding is that the wording in Article 274(3) which says “the exposure value of a netting set that is subject to a contractual margin agreement shall be capped at the exposure value of the same netting set not subject to any form of margin agreement” instead of meaning that there is no variation margin and hence this should be completely removed in the unmargined cap calculation should actually be read in conjunction with Article 272(12a) to define that in the absence of a margin agreement there can be nothing classed as “variation margin” and therefore all collateral is part of NICA – “NICA means the sum of the volatility-adjusted value of net collateral received or posted, as applicable, to the netting set other than variation margin”.   If we follow the previous Q&A answer then we will see significant reductions in RWA which we feel are unwarranted vs the counterparty risk for netting sets which exhibit the same portfolio dynamic as in the example above. The purpose of the cap is only to ignore exposure from large threshold amounts and not to avoid exposure from large amounts of posted collateral which are still owed back 

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

Standardansatz für das Gegenparteiausfallrisiko

Guten Tag Wir haben nun eine Unklarheit bezüglich dem CELEX 32019R0876, Art 274 Abs 5 a) Der Netting-Satz besteht ausschliesslich aus verkauften Optionen. Frage: Sind die verkauften Optionen aus Banksicht oder aus Kundensicht gemeint d.h. ist der Kunde short die Optionen oder die Bank ? Vielen Dank & freundliche GrüsseDenis Meylan P.S. Das EAD kann auf 0 gesetzt werden, bei einem reinen short Option Portfolio (aus Kundensicht oder Banksicht - darum die Frage).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio

Calculation of loss rates for income producing real estate (IPRE) under the standardized approach for credit risk under the CRR III (Regulation (EU) 2024/1619)

What is the correct calculation of loss rates for the purposes of Articles 125 para. 2 subpara. 3 and 126 para. 2 subpara. 3 CRR (as amended by regulation (EU) 2024/1623, ie. CRR III)?

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

Regulatory Reporting treatment in COREP of credit risk exposures linked to participated loans

Should exposures linked to loans participated in by other parties and de-recognised under IFRS 9 3.2.5 be reported as ORIGINAL EXPOSURE PRE CONVERSION FACTORS and mitigated by the amount received as the price paid for the participation or shall de-recognition allow the institutions to report ORIGINAL EXPOSURE PRE CONVERSION FACTORS equal to zero. 

  • 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)

Taxonomy 3.2: Is the validation rules v4745_s consistent for fair-value in short position disclosed in the cell C09.04, row 0040, columns 0010 ?

For information this request replace 2024_7015 In Annex II to Regulation (EU) 2021/451, chapter 3.4.3 referring to template C 09.04, the row of the line 0040  contains “Value of trading book exposures under internal models”. By this way, how to disclose the fair-value of a non-deritivative in a short position, in which the value is negative, whereas the CFV v4745_s expects only positive value used for long position ? Should this validation rule should exclude line 0040 ?

  • 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)

Taxonomy 3.2: Is the validation rules v4745_s consistent for fair-value in short position disclosed in the cell C09.04, row 0040, columns 0010 ?

In Annex II to Regulation (EU) 2021/451, chapter 3.4.3 referring to template C 09.04, the row of the line 0040  contains “Value of trading book exposures under internal models”. By this way, how to disclose the fair-value of a non-deritivative in a short position, in which the value is negative, whereas the CFV v4745_s expects only positive value used for long position ? Should this validation rule should exclude line 0040 ?

  • 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)

Regulatory Reporting treatment in COREP of credit risk exposures linked to participated loans

Should exposures linked to loans participated in by other parties and de-recognised under IFRS 9 3.2.5 be reported as ORIGINAL EXPOSURE PRE CONVERSION FACTORS and mitigated by the amount received as the price paid for the participation or shall de-recognition allow the institutions to report ORIGINAL EXPOSURE PRE CONVERSION FACTORS equal to zero. 

  • 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 SA exposure class (CRR Art 112) of the exposure amounts with an LTV ratio between 80% and 100%: secured or unsecured?

Art 125(2)((d) splits the secured part of a exposure secured by mortgages on immovable in a part with an LTV ratio lower than 80%, to which the 35 % risk weight is assigned, and a remaining part. The remaining part has an LTV ratio between 80% and 100% and gets the same treatment as the unsecured part. But should it still be considered a secured part of the exposure under art 112(i)?

  • 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)

Treatment of feature of tranching for mortgage backed securities

Under the US NPR,  the Fed has indicated that because the credit risk is to the agency and not the pool, the tranching doesn't count for CSR purposes, and thus the proper risk class to calculate is CSR_NS (not CSR_SNC). Banks in the US subject to FRTB have been following this convention as part of the Fed's Hypothetical Portfolio Exercise. Does the EU expect to follow this interpretation as well?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements

C 02.00 OWN FUNDS REQUIREMENTS CA2 - Row 0585

Hello,   As a bank reporting software company, we would like more information about FRTB.   In the Reporting framework 4.0, for Corep, for the template : C 02.00           OWN FUNDS REQUIREMENTS   CA2 We have a question about the row “0585- 1.3.4 Risk exposure amount for on- and off-balance sheet subject to market risk of entities applying only the Alternative Internal Models Approach (AIMA) or a combination of AIMA and ASA” There is a mention “See MKR AIMA SUM” in the “2.2 Annex II - Part II - Capital adequacy”   But the template “C 95.00     Alternative internal model approach: Summary of own funds requirements            MKR AIMA SUM” is postponed to 2026.   Can we conclude that this row is empty for 2025 ?   Thanks in advance,   Regards

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

Inclusion of Interim profits in CET1 ratio at half year

At the half year, where an institution has accrued for an interim cash dividend in line with its approved dividend policy and the policy also allows for the distribution of excess capital at the discretion of its Board, is the institution also required to deduct for a potential full year share buyback in its half year CET1 ratio where:  (i) its Board has not made any decision on an interim or full year share buyback and its distribution policy does not formally commit the institution to an interim / full year share buyback;  (ii) no share buyback application has been made to the ECB;  (iii) no explicit guidance on the quantum of a share buyback has been given to the market (at either the HY or FY), and therefore undistributed capital is fully available for use in H2 to cover unexpected risk or losses should they occur

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions

Counting of days past due in factoring arrangements.

As for non-recourse factoring, is it correct to start the counting of days past due based on the payment schedule defined or implied in the contractual terms with the client (i.e., the party from which the factor purchases the receivables)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR

The OFR calculation are performed in local currency (reporting currency in the jurisdiction for the subsidiary) and then converted to EUR (group reporting currency) for consolidation

Under current (No FRTB) Own Funds Requirements (OFR) framework for Market Risk. A bank composed by a parent entity in Europe and a subsidiary in a third country.  With approved use of Internal Model Approach for all risk factors where no offsetting of positions is allowed between both entities (parent and subsidiary) and not permission described in article 325 of CRR granted. Some residual risks calculated under Standardized Approach. So, according with the IMA permission and TRIM guides, the OFR calculation for market risk at consolidated level is the addition of 4 elements: OFR under IMA for parent + OFR under IMA for subsidiary + OFR under SA for parent + OFR under SA for subsidiary. For the subsidiary, the OFR calculation are performed in local currency (reporting currency in that jurisdiction) and then converted to EUR (group reporting currency) for consolidation. The required Banking Book positions (i.e. FX and commodities) are capitalized for market risk under this schema. Is this calculation compliant with CRR (current version of OFR, not FRTB reporting and future OFR)?

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

Meaning of ‘pure industrial holding company’ in the definition of financial institution.

How should the term ‘pure industrial holding company’ be understood in the context of the definition of ‘financial institution’ in accordance with article 4(1)(26) CRR? Would a holding company, the investments of which are exclusively outside of the financial sector, qualify as ‘purely industrial’ for the purposes of that definition?

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

Article 161(8) CRD

Has the EBA received a mandate from the Commission to explore whether Islamic financial sector entities are adequately covered by the CRD and the CRR? If so, has the EBA completed the report and provided a legislative proposal to the European Parliament and to the Council? If not, does the EBA have the authority to produce a report without a mandate from the Commission?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Treatment of repos and reverse repos with the same counterparty

How the unidentifiable collateral received and provided should be reported at LCR C74 and LCR C73 respectively? 

  • 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)

Excess of cash as part of reverse repo transaction

How should excess of cash as part of reverse repo transaction be reported in LCR C74 template?

  • 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)

Calculation of the capital requirements for structural FX risk

In the context of article 352.2, when there is an investment in a subsidiary denominated in foreign currency and this subsidiary has invested in other subsidiary denominated in the same foreign currency must this exposure be always exempted from capital requirements calculation? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/09 - Guidelines on the treatment of structural FX under Article 352(2) of CRR

Retail deposit - an established relationship criteria

For the purpose of article 24 paragraph 1(a) a retail deposit shall be considered to be part of an established relationship where the depositor meets at least one of the following criteria:  (a) has an active contractual relationship with the credit institution of at least 12 months duration;(b) has a borrowing relationship with the credit institution for residential loans or other long term loans;(c) has at least one other active product, other than a loan, with the credit institution.   Could you give an example what is considered to be 'one other active product, other than loan'?  Would it be correct to consider these products as 'one other active product, other than loan' to fulfill the crieteria c): credit card debt; hire purchase; financial lease ?

  • 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