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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

Application of a currency volatility adjustment in the case of a Significant Credit Risk Transfer securitisation

Should a currency volatility adjustment – as referenced to in CRR art 264 and defined in CRR art 223 - be applied in the case in which an originator synthetically securitises a partly non-EUR FX-denominated portfolio through the issuance of a EUR denominated fully funded Credit Linked Note?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/05 - Guidelines on significant credit risk transfer
  • ID: 2018_3849
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Use of short-term issuer credit assessments with Article 131

May short-term issuer ratings be used to assign risk weights in the context of article 131?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4941
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Applicable treatment of fair value changes for the identification of the applicable RW to exposures in default under the Standardised Approach

In the application of Article 127 CRR, should the credit risk adjustments embedded in the fair value be considered in the calculation of the percentage of the unsecured part of the exposure value represented by credit risk adjustments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2018_3785
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Interpretation of the term ‘ancillary services undertaking’ as defined in point (18) of Article 4 (1) CRR with a view to ‘intermediary undertakings’

Does the term ‘ancillary services undertaking’ as defined in point (18) of Article 4 (1) CRR include undertakings that act as an intermediary of business activities (‘intermediary undertakings’ or ‘brokers’), where those business activities themselves would lead to the qualification as an ‘institution’ as referred to in point (3) or a ‘financial institution’ as referred to in point (26) of Article 4 (1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3769
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Prudential backstop (Regulation 2019/630) and interaction with RWA calculation

Is the prudential backstop deficit under Article 151(1) taken into consideration for the calculation of risk-weighted assets on exposures treated under the advanced IRB approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4938
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Fair value changes due to changes in cross-currency basis spread eligible for CET1 capital (cost of hedging)

Are fair value changes due to changes in cross-currency basis spreads recognized in ‘other comprehensive income’, as referred to under IFRS 9 as the ‘cost of hedging’, eligible for CET1 capital under the CRR regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3715
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of 'explicit guarantee arrangements' for the purpose of classification of non-commercial undertakings as public sector entities

What conditions should be met by a given agreement in order to qualify as an 'explicit guarantee arrangement'?Shall the ‘explicit guarantee arrangements’ for the purpose of definition of public sector entities also be ‘guarantees’ eligible as unfunded credit protection or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3694
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

IFRS 9 transitional arrangements – calculation of the static component in case of afterwards permission for the IRB approach

If an institution gets the permission to use the IRB approach only after 1 January 2018 or the date of initial application of IFRS 9, as applicable, how should the institution calculate the amounts for the transitional arrangements permitted by Article 473a CRR and, in particular, the static component according to paragraph 2 of Article 473a CRR for those IRB exposures to which the standardised approach applied on the 31 December 2017 or the day before the date of initial application of IFRS 9, as applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4928
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Classification of direct reductions in the accounting value as credit risk adjustments

For the calculation of the exposure value in accordance to Article 166(1) CRR, shall the accounting value of credit exposures on the banking book (measured at FVTPL in accordance with IFRS 9) be increased by the amount of fair value adjustments?For the purposes of the treatment of expected loss amounts in accordance to Article 159 CRR, shall the credit risk related adjustments embedded in the fair value of the banking book exposures be considered as credit risk adjustments or other own funds reductions related to these exposures? How does this interact with the calculation of exposure value in accordance with Article 166(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2018_3662
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Classification of credit insurance undertakings as financial institution

Will a credit insurance undertaking whose principal activity is to issue guarantees (as listed in Annex 1 of Directive 2013/36/EC) be deemed to be a "financial institution"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4926
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Interpretation of the term “commercial immovable property” especially “other commercial premises” for the application of the preferential risk weights for the risk weight assets purposes according to the Article 126 of the CRR.

What is the definition of “other commercial premises” as commercial immovable property in Article 126 CRR for the purposes of application of preferential risk weights for the risk weight assets purposes, if all other conditions stipulated in the CRR are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3615
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Treatment of claims secured on residential property collateral

As claims secured on residential property collateral are excluded from the calculation of the total amount owed, can the deduction factor be applied to these claims secured on residential property collateral even though the remaining total amount owed by the obligor (group) exceeds the EUR 1,5 million? Or does it mean that once the remaining amount owed exceeds the limit all claims by the same obligor (group) are not eligible for the deduction?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3404
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Criteria for sufficiently diversified private equity portfolios under the simple risk weight approach

What rules should be applied in assessing whether a private equity exposure is in a sufficiently diversified portfolio of portfolio companies as mentioned in Article 155(2)?In case of exposure to several private equity funds, may the portfolio companies of these private equity funds be considered as one portfolio before assessing whether the portfolio is sufficiently diversified?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3371
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

’Appropriate prudential requirements’ with regard to ancillary services undertakings for the assessment of the condition in Article 113(6)(a) CRR.

Clarification is sought on the term “appropriate prudential requirements” with regard to ancillary service undertakings for the assessment of Article 113 (6) (a) Regulation (EU) No 575/2013 (CRR).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3365
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of subordinated exposures

What is the definition for subordinated exposures within the context of article 161?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3296
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Inclusion (or not) of a particular "timing loss" in the C 16.00 and C 17.00 template

Shall a particular "timing loss" in the Operational Risk Losses be included or not in the reporting template for operational risk?

  • 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)
  • ID: 2019_4920
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Application of a Permanent Partial Use exemption under Article 150(1)(d) to the European Commission

Does the permanent partial use exemption under Article 150(1)(d) of CRR encompass European organisations such as the European Commission? Does the permanent partial use exemption under Article 150(1)(d) of CRR encompass European organisations such as the European Commission?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3256
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

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: 2017_3241
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Deduction of deferred tax assets

Regarding the phasing-in percentages established in Article 478(2) of the CRR, how should the deduction amount  be calculated during the transitional period when part of the stock of DTAs existed prior to 1 January 2014?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3224
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022