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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

Calculating the threshold of 1% of total liabilities in significative currencies.

Should the institution report the section 2 of C 67.00 the total liabilities considering the complete scope of currencies in the bank or should be restricted to the total of the relevant significative currency. Moreover, this would have impact in the 1% threshold calculation.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4209
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/07/2020

Reporting of gains/losses other than dividends for investments in subsidiaries, associates and joint ventures (F 02.00).

Could you please provide further instructions about the reporting of gains/losses other than dividends for investments in unconsolidated (with respect to the regulatory scope of consolidation) subsidiaries, associates and joint ventures in the statement of profit or loss (F 02.00)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2019_4621
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Profit or loss on de-recognition of investment in subsidiaries, joint ventures and associates

Under IFRS, where in table F02 should “the gains or losses on de-recognition of investment in subsidiaries, joint ventures and associates” be recorded when they are neither classified (prior to the selling ) as “non-current assets and disposal groups classified as held for sale” nor their sale is considered a “discontinued operation” under IFRS5?

  • 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_4156
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Pre IFRS 9 Finrep - Template F07.00 reporting values as net or gross

Should the values reported in (pre IFRS9) Finrep template F07.00 columns 010-070, be on a gross or on a net basis?

  • 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_4015
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Separation of factors for strong customer authentication

If a mobile phone has two different e-banking apps on it, one for the banking agendas (a banking app where payments are initiated by entering password, possibly in combination with OTPs) and one for receiving the SMS OTPs (authorization app),would this scenario fulfill the PSD2 requirements of sufficient separation of both factors (since both factors reside on the same smartphone, but in different apps)?

  • 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: 2019_4637
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Exemptions from Strong Customer Authentication (SCA): credit transfers

Can the exemption under Article 15 of the RTS on SCA be applied to credit transfers between a personal account and a business account held by the same person.

  • 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: 2019_4564
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Unattended terminals and Transaction Risk Analysis (TRA) exemption and related Payment Service Providers (PSP)’s liabilities rules

Provided that both the payer’s Payment Service Provider (PSP) and the payee’s PSP can apply the strong customer authentication (SCA) exemption, without prejudice to the last say of the payer’s PSP, can a payment made at highway toll booths be treated as the one performed at the unattended terminals for transport fares?

  • 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: 2019_4480
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Scope of contingency mechanism

Should the interfaces – referred to in Article 33(4) of the RTS - be interpreted to include not only the internet banking interface of the account servicing payment service provider (ASPSP) but also its proprietary mobile banking interface?

  • 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: 2019_4826
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Define what is “given period of time”

What constitutes a “given period of time” as expressed in Article 4.3 (b) of the RTS on strong customer authentication and secure communication?

  • 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: 2019_4662
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

EBA register providing a list of third party providers (TPPs)

1° Does the EBA register under PSD2 provide a list of third party providers (TPPs)?2° If yes :2.1 Could you provide a procedure to get a TPP list?2.2 Should we filter on services 5 (Payment Initiation Service Provider (PISP) / Card Based Payment Instrument Issuer (CBPII) use case), 7 Account Information Service Provider (AISP) and 8 Payment Initiation Service Provider (PISP) to get the complete list of TPP?2.3 Agents can also provide services 5a, 7 and 8: In the downloadable JSON file, it is possible to find agents who are mandated by PSPs; however, the services offered by these agents are not indicated. Are the agents mandated by a PSP providing services 5A, 7 and 8 to be included in the TPP list?2.4 is the registry downloadable automatically? If yes, how?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2019/411 - RTS on EBA register under PSD2
  • ID: 2019_4650
  • Topic: Central register of the EBA
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Categories of Registration

Is it a requirement that all EU countries include the categories the institution is approved for within their respective registers i.e. in their publicly available data? Also are these categories available in a consistent and standard format across the EU such that anyone inquiring about a firm in more than one country has an easily recognisable and usable response

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/09 - Guidelines on authorisation and registration under PSD2
  • ID: 2018_4371
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Dynamic linking: transactions for which the final amount is unknown and may be lower or higher than authenticated amount

For remote card transactions, is it acceptable that there are legitimate cases where the final amount may be lower or higher than the amount authenticated by the cardholder?

  • 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: 2020_5133
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/05/2020

Calculation of foreseeable dividend to be deducted from interim profits when interim dividend has been paid

How exactly is the amount of interim profit to be included in Common Equity Tier 1 calculated according to Article 2(2) to (4) of the Regulation (EU) 241/2014 when the interim dividend has already been paid out and yet no final divided has been formally decided or proposed to the institution’s relevant body?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4477
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/05/2020

Large Exposures treatment of Nostro Accounts used for correspondent banking

Do Nostro Accounts used for correspondent banking activities always meet the exclusion criteria specified under Article 390(6) CRR?To the extent that a low amount of exposure is always left in the same accounts, as a buffer to avoid going overdrawn as a result of the correspondent banking activity, would this be eligible for the exclusions as well? If yes, under which circumstances?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4805
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 15/05/2020

Timing of recognition of year-end profits in CET1 for the purpose of COREP reporting and Pillar 3 disclosure

What is the correct timing for the recognition of year-end profits in CET1 for the purpose of COREP reporting and Pillar 3 disclosure, in the case that a bank does not request prior permission of the competent authority for inclusion of interim or year-end profits in CET1 pursuant to Article 26(2) of the CRR?

  • 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_4085
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/05/2020

Inclusion of interim profits in CET1

After the competent authority (CA) granted a permission to include interim profits in CET1 on the basis of the Article 26(2) CRR, on what date do these interim profits become part of CET1 capital?

  • 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
  • ID: 2018_3822
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/05/2020

Quantification of foreseeable dividends when the dividend policy is set as a fix amount

Which amount should be deducted from interim/year-end profits pursuant to Article 26(2) CRR if a bank has a dividend policy stating that a certain specified amount (i.e. x.xx €) should be paid per share?

  • 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
  • ID: 2019_4731
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/05/2020

Signature on a paper slip from a payment terminal, as a factor in a two-factor SCA

Could Signature on a paper slip from a payment terminal, be considered a valid factor in a two-factor strong customer authentication (SCA) under the RTS – and what type of element is it?

  • 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_4237
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/05/2020

HQLA treatment of euro-denominated assets held in 3rd Countries

In the LCR DA, and subject to compliance with the caps in Article 17, can all Euro denominated net liquidity outflows of a credit institution, irrespective of where they arise, be covered by euro denominated Level 1 HQLA envisaged in Article 10(1)(d) and by Level 2b HQLA envisaged in Article 12(1)(c)(ii), in the latter case if not denominated in euro nor in the currency of the credit institution’s home Member State?

  • 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_4285
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/05/2020

HQLA and amortised cost classification

If a bank holds HQLAs in the amortised cost portfolio and is able to monetise these assets can the securities, e.g. government bonds, in the amortised cost portfolio also be treated as HQLA in LCR calculation?

  • 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_3955
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/05/2020