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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

Presentation of cash flows related to non performing exposures in the template (C 66.01.a)

It is not clear how to interpret the following instruction: “17. Past due items and items for which the institution has a reason to expect non- performance shall not be reported.”

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2018_3794
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Application of the exemption related to a trusted beneficiary

Has the exemption related to a trusted beneficiary to be applied on an account basis or rather to a list of accounts included in an online banking agreement ? Whose list has to be considered in case of a power of attorney where the initiator is not the account owner ? What happens in case of a shared account where each one holds his own trusted beneficiary lists ?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4360
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/03/2019

Applicability of SCA to ‘card payments initiated by the payee only’

Are card payments that are initiated by the payee only on the basis of (1) an initial mandate by the payer authorizing the payee to initiate the periodic payments and (2) a pre-existing agreement between the payer and the payee for the provision of products or services, subject to the RTS SCA requirements?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4031
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Subsequent instances of a recurring card payment transaction, other than the first, initial one, are transactions initiated by the payee only. This is also the case for card instalment transactions.

Are the subsequent instance of card payment recurring transactions (other than the first, initial one) and of instalment transactions (again, subsequent to the initial one) transactions initiated by the payee only?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4404
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Payee-initiated transactions with irregular period or variable amount

Please clarify whether standing agreements between a customer and a merchant resulting in subsequent billing (irregular or otherwise) to be payee-initiated transactions, and as such excluded from the SCA requirement.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4131
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Transactions initiated via Interactive Voice Response (IVR) solutions

Do transactions initiated via Interactive Voice Response (IVR) solutions qualify as telephone orders and are therefore excluded from the scope of the RTS SCA requirements?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4058
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Exposures to unrated institutions

How should exposures to unrated institutions be treated under Article 121 CRR in the cases where these institutions are located in a Member State or in a third country that does apply supervisory and regulatory arrangements at least equivalent to those applied in the Union and the exposures to the central government and central bank denominated and funded in domestic currency are assigned a risk weight according to Articles 114(4) to (7)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3765
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Exposures to regional governments, local authorities or public sector entities which are treated as exposures to central governments under Articles 115 and 116 CRR

Please clarify how Article 115(2) CRR shall be applied in case regional governments and local authorities are treated under the SA by application of Article 150 CRR and central governments are treated under the IRB Approach. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3517
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Does SCA apply to electronically processed SEPA Direct Debits ?

When processing SEPA Direct Debits electronically (assuming that the Direct Debit mandate has been signed digitally), does SCA apply to transactions? If not, what is the legal basis for this exemption?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4359
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 22/02/2019

New risk weights for exposures to central governments or central banks not applicable in DPM 2.7 for C 07.00

How should the new risk weights be applied when they are not currently available in the DPM 2.7?

  • 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: 2018_3947
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/02/2019

Treatment of off-balance sheet exposures measured at reporting date at fair value trough P&L in templates F 18.00 and F 19.00

How should we treat off-balance sheet exposures measured at reporting date at fair value trough P&L from the reporting templates F 18.00 and F 19.00 point of view? Shall we include them into templates or not?

  • 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: 2018_3912
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 22/02/2019

Reactivation of v0191_m as of v2.7.

Is the reactivation of v0191_m: {C 01.00, r370, c010} = {C 05.01, r170, c060} 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)
  • ID: 2018_3887
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/02/2019

IFRS 9 Transitional arrangements – Calculation of the total exposure measure of the leverage ratio

According to Article 473a(7)(b) of CRR, is it correct to adjust the specific credit risk adjustments by applying a scaling factor for the only exposures subject to the standardised credit risk approach for the purpose of the calculation of the total exposure measure of the transitional leverage ratio?

  • 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
  • ID: 2018_3995
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 15/02/2019

On demand secured lending of Level 1 assets

Can Level 1 assets that are used for on demand secured lending transactions be considered as liquid assets for the Liquidity buffer?

  • 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: 2018_3730
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Contactless payments at point of sale - Applications of the conditions

What activity can be considered a proper application of strong customer authentication according to the Article 11 Paragraph b of the Commission Delegated Regulation (EU) 2018/389?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4226
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Reporting of assets sold short as a additional outflow for LCR under Delegated Act

For the purposes of reporting additional outflow for short positions in the LCR (row ID 1.1.45.6.2) on the C73 return, are firms required to report both unsettled and settled uncovered sold short positions?  

  • 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: 2016_2585
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Communication plans to inform payment service providers making use of the dedicated interface

Is it sufficient to publish the measures to restore the system and the further descriptions on the website in an area, which is secured by the certificates of the payment service providers?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4071
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Length of authentication codes

Is a 3 decimal-digit authentication code, which (1) is unique per each transaction and (2) complies with the other security requirements set out in Article 4 RTS, compliant with the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4053
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Showing a password after it has been masked

Article 22, 2(a) states that "personalised security credentials are masked when displayed and are not readable in their full extent when input by the payment service user during the authentication". Is it ok to offer the user a "show password"-button, so the user can verify that correct password has been entered, before fulfilling an authentication?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4366
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/02/2019