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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

Gamma correlations regarding curvature risk in low and high scenario

To calculate the gamma correlation to be used for the curvature risk in the low and high scenarios, should institutions at first square the gamma correlation used for the delta risk and then apply the formulas provided for in Article 325h CRR or vice versa?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6122
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Simultaneous applicability of non-deduction exemptions under Articles 48 and 49 CRR regarding equity exposures on insurance holdings where an institution has a significant investment

For an institution that has received permission to apply Article 49(1) CRR, has a significant investment below or equal to the threshold indicated in Article 48(1) and 48(2) (exempted from being deducted from Common Equity Tier 1 according to Article 49(1), are the amounts of holdings in insurance undertakings, to be risk-weighted at 250% according to Article 48(4) and the amounts of such holdings that are above this threshold risk-weighted in line with Article 49(4)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5664
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Treatment of Repo and Reverse repo with bilateral early termination option

A supervised institution has entered a reverse repo with a financial counterparty which features an early termination option exercisable at the supervised institution’s discretion. In order to be able to map the reverse repo on the option date for the purpose of NSFR - RSF calculation, how are the supervised institution and the competent authorities supposed to assess the reputational factors that may limit the institution’s ability to exercise the option? [ref. Article 428q 3.]

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5588
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Calculation of NPV loss in case of (internal) refinancing

Which NPV loss should be taken in order to calculate the NPV loss if the 1% threshold is breached and the forborne loan contract should be placed in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2021_6045
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Assignment to grades or pools

Do the requirements in Article 171(2) CRR refer to the Estimation of Risk Parameters or to the Application of Risk Parameters?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5761
  • Topic: Model validation
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Application of Required Stable Funding on the basis of Guarantees Received

Where a loan is made to a non-financial corporate, and the loan is guaranteed by a financial counterparty such that the credit exposure on the loan is viewed by the firm as an exposure to the guarantor (financial counterparty), can the 10% RSF applicable under CRR Article 428v be applied to such a transaction?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5574
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Aggregation of separate client exposures for a transaction with underlying credit risk exposure

Is it necessary to group and aggregate all separate client exposures from a single transaction with underlying credit risk to one exposure and, as such, treat this aggregated separate client as a single client exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets
  • ID: 2021_5746
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Use of UTP triggers when default definition is on facility level

If an obligor has a mortgage loan and other loans (like credit card, private loan, business loans etc.) where definition of default is on the facility level, and the institution has certain obligor level triggers (bankruptcy, death, divorce etc.) and the obligor defaults on his mortgage (due to an obligor level trigger), should there be an automatic cross default on the other loans as well. If the opposite happens, i.e. the obligor defaults on one of the other loans (also due to an obligor level trigger) should the mortgage be defaulted as well?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2020_5592
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

LCR treatment of maturing securities issued by the reporting credit institution

What is the LCR treatment of maturing securities issued by the reporting credit institution where these securities are treated as deposits for the purpose of accounting?

  • 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: 2020_5518
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Excess collateral held by credit institution that can be contractually called at any times by the counterparty

Do we need to consider all future derivatives inflows or only the future derivatives inflows within the 30-day LCR bucket for the calculation of excess collateral?

  • 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: 2020_5544
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Original maturity for off-balance sheet items

How is the „original maturity” identified for items in CRR Annex 1 (2)(b)(ii)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5297
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Issues related to para (89) of the EBA/GL/2017/16 with regards to the calibration procedure of the PD models to be conducted “after taking into account any overrides applied in the assignment of obligors to grades or pools”

With regards to the interpretation of the requirement reported in paragraph (89) of the Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures (EBA/GL/2017/16), is it correct that if a ranking method or overrides policy has changed over time, the institutions cannot “conduct the calibration after taking into account any overrides applied in the assignment of obligors to grades or pools”, because the relevant data is not available (e.g. in case of a model change the rating produced by the new PD model cannot include the override process)? With regards to the interpretation of the requirement reported in par. 89 of the GLs, is it correct that if a ranking method or overrides policy has changed over time, the institutions should “analyse the effects of these changes on the frequency and scope of overrides and take them into account appropriately” in the annual review of estimates framework, once the relevant data becomes available, meaning that the new rating attribution process has been fully deployed and used by the analysts of the Supervised Entity?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2019_5029
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Callable deposits from financial institutions to be included in LCR with the entire outstanding

Are deposits from financial institutions considered callable and should therefore they be included in LCR for their entire outstanding amount, regardless their maturity?

  • 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: 2020_5287
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Definition of retail deposits which meet conditions from Article 25(2)(d) LCR Amending Act

Which maturity shall be taken into account at assessing if deposit meets the conditions from Article 25(2) (d) of the LCR amending Act, the original maturity of the originally placed fixed-term deposit or the residual maturity of the present fixed–term deposit? What is the meaning of term "originally placed"? Can the deposit meet conditions from this Article if it wasn't originally placed as fixed-term deposit but was later prolonged as fixed-term deposit and will mature in next 30 calendar days?

  • 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: 2020_5107
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Consolidated supervision

At how many levels should consolidation according to Article 11 CRR be done by a single institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4957
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Risk weight attribution to loans guaranteed by third counterparties in NSFR

If a credit institution has granted loans to customers (Retail, SME or Corporate counterparties) where the customer has a guarantor for the loan (personal guarantees), which is a Sovereign/PSEs or a third financial institution, what risk weight should be attributed to those loans for purposes of NSFR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4951
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Residential Reverse mortgages RWA

Could you clarify the regulatory RWA treatment for residential reverse mortgages exposure? Are those exposures subject to the standardised approach for RWA calculation?Is the regulatory treatment linked to the level of loan to value (LTV) the same as residential mortgages?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4934
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Calculation of the number of obligors

In EBA/GL/2017/16 paragraph 73 it is explained that in the calculation of the one-year default rates the number of obligors is used. Is it always mandatory to count one legal entity as one obligor, or can a group of legal entities for which there is no difference in risk due to an appropriate guarantee (i.e. those will default together) be counted as one obligor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2019_4599
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Unutilised Limits of Guarantess

Are the unutilised limits of guarantees to be included in LCR {C73,r870,c010}?

  • 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: 2019_4872
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Interim profits attributable to minority shareholders

Is the prior permission of the competent authority needed at individual level of a subsidiary to include in the consolidated CET1 items the interim profits of that subsidiary attributable to minority shareholders?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4734
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/02/2022