Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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

OSII capital buffer

Is Article 131(8) of Directive 2013/36/EU applicable on a situation, where an Other Systematically Important (“OSII“) institution in a member state is a member of a OSII group with no EU parent institution, but with an EU parent financial holding company in another member state instead?

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

High income OECD countries and Liquid asset classifications

Can high income OECD countries’ Government bonds be considered as Level 1 assets for the purposes of the LCR?

  • 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

Treatment of inflows from credit facilities in LCR

If an institution expects that a credit facility is prolonged when it becomes due or a renegotiation date occurs, should institutions report an inflow at the due/renegotiation date?Shall institutions report interest payments on credit facilities as inflows if customers do not pay interests in cash?

  • 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

Liquid assets underlying sold call options

Should bonds underlying call options (either American or European expiring within 30 days; with exercise mode physical delivery) written by the institution be considered as used in hedging strategies, thus excluding them from the holding of liquid assets in the context of LCR reporting?

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

Third countries considered to have supervisory arrangements equivalent to EU

Article 11 of Delegated Act 2015/61 specifies the conditions under which covered bonds can be considered buffer L2A eligible. For covered bonds issued by credit institutions in third countries, Article 11(1)(d)(ii) requires that “supervisory arrangements applied in the third country must be at least equivalent to those applied in the Union”. Could you please indicate us if a list of such countries will be made available?

  • 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

Validation rule v4795_m, C 13.00 - Securitisations

In the case where an institution did not originate any positions in a securitisation what values should be reported in column 010 of template C13.00?

  • 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)

V4835_m - C 19.00 column 610 calculation

We have interrogations about the new validation rule v4835_m. In C 19.00, row 010: column 610 = column 600 (TOTAL OWN FUNDS REQUIREMENTS = SUM OF WEIGHTED NET LONG AND SHORT POSITIONS).Until now, some of our clients calculates column 610 multiplying column 600 by 8%. In ITS and Article 337 (4) CRR, we saw only the following precision: c600 is used to calculate c610 but there is no precision on this calculation. From 2015 onwards according to Article 337 (4) of CRR, the institution shall sum its weighted net positions, regardless whether they are long or short (column 600), in order to calculate the own funds requirements.Could you clarify the calculation of the column c610 in C 19.00?

  • 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)

FINREP (IAS 39), Validation rules v5014_m

Validation rule v5014_m talks about the total of loans and advances of Non financial corporation reported in template F 06.00 that should be equal to       template F 18.00 (Gross exposure) in Non financial corporation for loans and       advances at amortised cost+     template F 18.00 (Gross exposure) in Non financial corporation for loans and advances at fair value other than HFT+     template F 04.01 in Non financial corporation for loans and advances held for trading./.    template F 04.01, amount of cumulative changes in fair value attributable to changes in credit risk for NFC.Since, the above rule is only considering the gross exposure in Non financial corporation. So, why we are deducting the amount for cumulative changes in fair value attributable to changes in credit risk. That will create delta.

  • 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)

EBA validations APPEAR to be relevant to IFRS and GAAP though they only include a GAAP template (F 04.06)

Can you confirm that these validations are out of scope for IFRS and, if so, why in the EBA validations list their severity is marked as "Blocking for IFRS"?

  • 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 07.00, column 230: of which: with a credit assessment by a nominated ECAI

We would like to know that whether ECAI rated CRM will be considered to report this column.Case: Unrated Corporate customer pledges ECAI rated debt instruments. Will this exposure be reported in column 230?

  • 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 v3950_s for nGAAP

For some Institution, which don't follow the IFRS recommendations respective interest income on liabilities and interest expense on assets it might happen,,that they show negative interest income. Because according to Austrian GAAP it it is allowed, that negative interest rates reduce interest income and might turn negative. So v3950_s can not be fulfilled in some cases and therefore v3950_s should be "non-blocking" for nGAAP reporters.

  • 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)

Partial and Total-Write-Offs in FINREP IFRS 9 templates F 04.03.1 and F 04.03.2

FINREP Forms F.04.03.1 and F.04.03.2 require the disclosure of partial and total-write offs in columns 080 and 090. Reference is made to IFRS 9.5.4.4 and B5.4.9 and Annex V.Part 2.72-74.Both references are however silent, as to how long the disclosure about in particular total write-offs is required. Is the disclosure of total write-offs only required in the year, when the total-write off has occurred? (Rationale: A (total) write-off constitutes a derecognition event - a disclosure for instruments no longer recognised does not make sense in the following year).Alternative view: Guidance in Part 2.72 is equally valid for partial and total write-offs. This means, the amounts in columns 080 and 090 ‘shall be reported until the total extinguishment of all the reporting institution’s rights by expiry of the statute-of-limitations period, forgiveness or other causes, or until recovery’, i.e. as long as ‘they are subject to enforcement activities’. This would mean, that partial write-offs would NOT be required to be reported, if a certain amount (e.g. 50%) was forgiven and therefore written off and is therefore also no longer enforced. Simultaneously, even total-write-offs would have to be reported, as long as enforcement activities are undertaken, also in later years. This view however seems to be somewhat in contradiction with IFRS 9.B.5.4.9, which stipulates that write-offs should only occur, ‘if the entity has no reasonable prospects of recovering any further cash flows from the financial asset’. Thus, the column would have to be filled in only in the very rare cases, where ‘the entity has no reasonable prospect of recovering any further cash flows from the financial assets’, but still undertakes enforcement activities.Is this interpretation 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)

Reconciliation of FINREP and COREP with regard to goodwill

May the amounts of goodwill reported in FINREP and COREP differ due to differences in treatment between the accounting framework and 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)

Asset encumbrance Reporting vs. Finrep Reporting – Definition of equity instruments not aligned

The following validation rule is not correct:v2816_m: sum({F 32.01, r030, (c010, c060)}) = sum({F 01.01, c010, (r070, r093, r110, r150, r172, r176, r235)})’.This validation rule excludes row 260 of F 01.01. An entity has to disclose ‘Investments in subsidiaries, joint ventures and associates’ in this row.By definition, row 260 of F 01.01 includes equity shares that are representing the ownership in subsidiary, joint ventures or associates.

  • 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 outflows and Inflows arising from secured lending transaction where collateral is not Level 1, Level 2A and Level 2B asset on DA LCR templates C 73.00 and C 74.00

On which rows of the liquidity coverage templates C 73.00  - Outflows and C 74.00 - Inflows should firms report flows arising from secured lending transaction where collateral is not Level 1, Level 2A and Level 2B asset and therefore non-liquid asset. ANNEX XXV – REPORTING ON LIQUIDITY (PART 2 OUTFLOWS) and ANNEX XXV – REPORTING ON LIQUIDITY (PART 3: INFLOWS) state that ‘Credit institutions shall only report the Level 1, Level 2A and Level 2B assets that qualify as liquid assets in accordance with Title II of Commission Delegated Regulation (EU) 2015/61. Where collateral is Level 1, Level 2A or Level 2B but does not qualify as liquid asset in accordance with Title II of Commission Delegated Regulation (EU) 2015/61 it shall be reported as non-liquid.’Therefore are firms not required to report flows arising from secured lending transaction where collateral is non Level 1, Level 2A and Level 2B asset in section ID 1.2 of the C 73.00  and C 74.00 on the rows for collateral that does not qualify as a liquid asset? The specific remark regarding secured lending and capital market-driven transactions on ANNEX XXV – REPORTING ON LIQUIDITY (PART 3 INFLOWS) 1.2 (3) is ambiguous when viewed in conjunction with the decision tree guidance for reporting assets and liabilities from secured lending which states ‘Allocate into one relevant item of ID 1.2’.If firms are not required to report flows arising from secured lending transaction where collateral is non Level 1, Level 2A and Level 2B asset in section ID 1.2 of the C 73.00  and C 74.00 where should they be reported? We assume they must be reported somewhere as they contribute to the firms’ net liquidity outflow, but to report these flows in section 1.2 can distort the numerator calculation on row 090 of C 76.00.

  • 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)

Reporting of individual exposures relating to a group of connected institutions for which there is a cash pooling agreement, where some creditor nostri accounts are offsetting debtor nostri balances

Our institution has a cash pooling agreement relating to three bank accounts opened in different banks belonging to the same Group, so that cash transfers are processed automatically overnight to one centralizing bank account.Up to now, in the LE2 template, we have been reporting the resulting net exposure on this group of connected counterparties and in the LE3 template, the detail for each of the three counterparties, but we have been encountering the following validation rule blocking errors: v0648_m, v0649_m,  v3799_s and v3802_s. These errors are due to the input of a negative outstanding for one of the banking counterparts, corresponding to a creditor nostro balance.Our question is how to fill in the LE3 template in this situation ?

  • 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 22.00 (Market Risk FX) - Scope of Memorandum Items

Please clarify whether the Memorandum Items on COREP template C 22.00 (Market Risk FX) which are to be reported on rows 130 and below should include all of an institution's gross and net FX positions, regardless of the approach used for capital requirements of these positions. Please also clarify whether these items should be reported by all institutions with the relevant COREP reporting requirement, or only by those institutions which meet (i.e. exceed) the 'de minimis' threshold defined in Article 351 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)

Inconsistency between Annex II C 14.00, column 190 and DTS categorisation of COREP C 14.00, ei86 measure.

In return C 14.00, the Annex II states that ‘If no country exceeds a 20 % threshold based on the amount of assets/liabilities, then ‘OT’ (other) shall be reported.’This would imply that ei86 must report ‘OT’ value.Measure ei86 has link to GA domain, GA4 hierarchy.The GA4 doesn't contain ‘OT’ member. It contains eba_x28 - Other Countries member.We believe there to be an inconsistency between the GA4 hierarchy and the Annex II.

  • 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)

Consideration and representation within the LE templates in case of existing indirect exposure resulting out of credit risk mitigation (CRM) – here unfunded credit protection under a guarantee between two partners within a Group of connected clients (GCC).

In case of large exposures to a Central Government (SOV) which is part of a Group of Connected Clients (GCC) according to CRR Art. 4 para 1 (39) and reported as explained in the Q&A 2013_681 (separate aggregation of the SOV and each GCC), in which way would be a guarantee considered if the SOV is the guarantor of the entity A and they are both part of the same GCC?We see the following options:the indirect exposure towards the SOV is reported for each Group of connected clients (e.g. GCC1 consisting of SOV and entity A and GCC2 consisting of SOV and entity B) and the direct exposure and the effect from credit risk mitigation is reported only to entity A;in this case there is double counting of the exposure (SOV+A) when calculating the original exposure and the exposure before CRM and exemptions of the GCC;the indirect exposure towards the SOV is reported for each Group of connected clients (e.g. GCC1 consisting of SOV and entity A and GCC2 consisting of SOV and entity B) and the direct exposure to A is omitted (being part of the same GCC): in this case there is no double counting of the exposure (only exposure to SOV);the indirect exposure towards the SOV is not reported at all while the direct exposure to A is reported (out of the existing intragroup guarantee there is no effect from CRM): in this case there is no double counting of the exposure (only direct exposure to A).

  • 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)

Definition of encumbrance relating to retained interest of the issuer of securitisations

Does the ‘underlying retained securities’ of a securitization position include retained interest of the issuer as defined in article 405 of CRR? Does the retained interest of the issuer shall be considered as encumbered?

  • 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)