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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.

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List of Q&A's

Reporting of currency for undrawn committed facilities in Concentration of Counterbalancing Capacity template C 71.00

What currency identifier should be reported on template C 71.00 for an undrawn committed facility that is available to draw in multiple currencies and how should it be reported on significant currency returns?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Prices for Various Lengths of Funding-currency spreads

We would like to seek further guidance on whether the EBA expects firms to calculate spreads for all currencies, which would then be used to calculate the total, or if the EBA would accept reporting for material funding only?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

References to items covered by a Deposit Guarantee scheme in the instructions on r070 and r090 of C 68.00

Is the text of Annex XIX in the final draft ITS 680/2014 and DPM 2.7 ITS on supervisory reporting correct when it refers to ALMM C 68.00, items 1.4 and 1.4.2 as ‘savings accounts without a notice period for withdrawal which is greater than 30 days covered by a Deposit Guarantee Scheme according to Directive 2014/ 49/ EU or an equivalent deposit guarantee scheme in a third country’?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Cap on the own funds requirement for a net position

Article 335 refers ‘The institution may cap the own funds requirement for specific risk of a net position in a debt instrument at the maximum possible default-risk related loss.....’. This article suggests that the Specific Risk requirement in column 060, rows 260 to 320 (column 060) of template C 18.00 should be the adjusted ‘capped own funds requirement’ and reduced to the maximum loss.However, the validation rules v0578_m and v0579_m require that column 060, rows 310 and 320 are the result of column 050 multiplied by 0.08 or 0.12. Of course, capping and adjusting the specific risk breaks these rules and prevents submission. Should the requirement itself be reduced or should the Net position in column 050 of the relevant rows be adjusted?

  • 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)

Validointissääntö e4900_n, C 07.00 Standardimenetelmän mukaiset pääomavaatimukset (Validation rule e4900_n: C 07.00 Capital requirements according to the standard method)

Original questionMillä lomakkeen C 07.00 rivillä ryhmän sisäiset katetut joukkovelkakirjat pitää ilmoittaa? English translationOn which row of form C 07.00 should intra-group covered bonds be indicated?

  • 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)

Amended validation rule v3693_s in v2.6

According to the amended validation rule column 060, row 010 of template C 05.01 should be reported as greater or equal to zero.On the other hand, the ITS sign convention states any amount that increases the own funds or the capital requirements shall be reported as a positive figure while any amount that reduces the total own funds or the capital requirements shall be reported as a negative figure.In our example given in ‘Background on the question’ box, row 010, column 060 (Total adjustments) represents net deductions and therefore is to be reported as negative. In fact in EBA Q&A 2015_2482 it states that those rows of column 060 which show deductions according to final provisions are reported with a negative sign.

  • 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)

Validation rule v4886_m

A new validation rule v4886_m has been added to taxonomy 2.6 which specifies that : [C 03.00 (r010;030;050;070-120)] {c010} < 1 This rule fails to consider that a firm may hold surplus capital for other purposes (such as Large Exposures) that would cause failure of this rule.

  • 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)

Value assigned to liabilities arising from derivative contracts

For the purpose of Article 5(3) of Commission Delegated Regulation (EU) 2015/63 the valuation of derivative contracts should be done in accordance with the methodology specified in Article 429(6) and (7) of Regulation (EU) No 575/2013 (CRR) [as amended by Commission Delegated Regulation (EU) 2015/62].How should this methodology be applied when adjusting the liability side, i.e. derivative contracts with a negative market value?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements

Treatment of expected loss amounts in validation rule v4772_m

Is validation rules v4772_m correct?

  • 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)

Template C 17.00 (OPR Details) - Reporting on loss adjustments

How should we interpret and treat the negative loss adjustment within the total loss amount?How should we treat the total loss amounts compared to the top loss events and the max single loss?

  • 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)

Incorrect validation rules v4779_m and v4782_m

The question relates to the validation rule 4779_m and v4782_m implemented in DPM 2.6 and 2.7. Currently these validations are applied to all figures reported on rows 110 and 070 for all sheets and all columns. But as columns 080, 090 and 100 are used to display weighted PD or LGD, those columns must be excluded from validations v4779_m and v4782_m.Having a weighted PD of 52% on SME and a weighted PD of 50% on non SME doesn’t mean that the global weighted PD of the ‘Secured by real estate property’ will be of 102%. The global PD for such exposure class will be between 50 and 52%. If you agree, even if this rules are non-blocking, can you please deactivate them? And correct them for the next release?

  • 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)

New EBA Validation rule (taxonomy 2.6) v4786_m about the comparison between the risk weighted exposure amount and the exposure value for Equity in CR GB IRB

According to the validation rule v4786_m, c105 shall be greater than or equal to c110 in all rows and all sheets in C 09.02, i.e. the exposure value (c105) has to be higher than the risk weighted exposure amount (c110).However, in accordance with Article 155 paragraph 2 of the CRR, the risks weights are equal to 190% for private equity exposures in sufficiently diversified portfolios, 290% for exchange traded equity exposures and 370% for all other equity exposures.For the row 140 ‘Equity’ in template C 09.02, as these rates are higher than 100%, the exposure value can be less than the risk weighted exposure amount and the rule cannot be respected.Could you please exclude the rows 140 ‘Equity’ and 150 ‘Total Exposures’ from the rule?

  • 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)

C 09.02 - validation rules v4776_m, v4777_m, v4778_m, v4780_m and v4781_m

According to validation rule v4776_m, the value in row r060 of C 09.02 should be >= the value in row r070 and this for columns (010-070;100-130). We think this rule is only relevant for columns which report amounts and not for columns which report percentages. Hence, we think this rule cannot be applied to column c100 as this column is used to report an average LGD in %. The same remark applies for validation rules v4777_m; v4778_m; v4780_m; v4781_m.

  • 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)

Transactions with maturities longer than 10 years

We reference to the Q&A 2015_1802: Transactions with maturities longer than 10 years are excluded in the form C 69.00. Does the excluding of transactions with maturities longer than 10 years also apply for the form C 70.00?

  • 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)

Scope of bail-in tool: Clarification on Article 44(2)(f)

Is the purchase or sale by an EU bank (falling within the EU Single Supervisory Mechanism) from/to a EU bank (also subjected to the EU Single Supervisory Mechanism) of a listed security (bond of equity) with settlement T+2 (up to T+6) through a clearer such as (but not limited to) Euroclear, Iberclear, Clearstream, Monte Titoli, Sicovam, etc... excluded from bail-in in force of Article 44(2)(f) of the Directive 2014/59/EU?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C 17.01 – Total gross losses and loss adjustments (v6127_h and v6128_h)

In the new version of the ITS available on the EBA website which explains the functional requirements regarding the DPM 2.7, it's stated in the presentation of rows 010-880: ‘Institutions that calculate their own funds requirement according to BIA can report those losses for which the business line is not identified in rows 910-980 only.’In the definition of row 910, the ITS clearly states: ‘It may be higher, if an institution calculating its own funds requirements according to BIA cannot identify the business line(s) affected by the loss in every case. [...]'.This definition make sense for us, as it pastes with the requirement defined above mentioning that BIA losses may in certain cases only affect rows 910-980.But in the same case the definition of row 920-924 and the validation rules v6127_h and v6128_h seem to indicate that row 920 and 940 must be calculated as simple aggregation of the previous rows: ‘the gross loss amount (new events) reported in row 920 is the simple aggregation of the gross loss amounts of new events for each business line.’ Such indications for us are not consistent with the previous one indicating that for BIA only the total section may be fed.Please can you tell us in case of losses calculated under BIA with no business line attached how we should feed them in the C 17.01?

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

Classification as off-balance sheet items of a committed reverse repo facility or other committed credit facilities where drawing under the facility is conditional upon purchasing or receiving eligible collateral

Would it be possible for an institution to assign a committed reverse repo facility, or other committed credit facility where drawing by the client is conditional to purchasing or receiving eligible collateral by the institution, to one of the risk categories as “other items also carrying [low], [medium/low], [medium] risk and as communicated by EBA”, in accordance with Article 111(1) CRR or Article 166(10) CRR and Annex I?

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

CCF for uncommitted lines

Can uncommitted guarantee/letter of credit lines be classified as low risk under Annex I, point 4 letter (c) CRR? 

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

Presentation of IRB floor (Article 500 CRR) in COREP templates

How should an IRB institution present Basel I floor as defined in Art. 500 CRR (an additional IRB floor requirement) in COREP reports?

  • 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)

Reporting of credit risk adjustments according to Article 110 of CRR

In relation to SA General credit risk adjustments, as per template C 01.00, row 920, column 010, is an institution also required to report the respective values in column 050 in template C 09.01?Furthermore, should this credit risk adjustment apply for a bank and the bank is not including it in its Tier 2 capital, is the NCA obliged to inform the bank accordingly?

  • 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)