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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

Applicability of exemption under RTS Article 11 for payee’s PSPs (acquirers)

Can an exemption under Article 11 of the RTS on strong customer authentication and secure communication be applied by the payee's payment service provider (PSP) (the acquirer) for card-based payments?

  • 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_4241
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Contactless counting

For the purpose of counting previous cumulative contactless transactions in order to assess the eligibility of the exemption in Article 11 of the RTS, should contactless transactions initiated outside of the EEA be included?

  • 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_4227
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Contactless payments at point of sale - Applications of the conditions

With respect to Article 11 Paragraph b) of the RTS can we setup control for either 150 € or 5 transactions?

  • 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_4225
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Application of limits for Strong customer authentication (SCA) exemption

How should payment service providers (PSPs) apply the cumulative limits set in Articles 11 and 16 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: 2018_4182
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Application of the low-value contactless exemption – Calculation of limits at Primary Account Number (PAN) / account level or at device / token level

May the counters for the application of the low-value contactless exemption be calculated at device/token level?

  • 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_4036
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Criteria for the application of the transaction risk analysis (TRA) exemption – Relevant fraud rates

Is only the Payment Service Provider (PSP) applying the TRA exemption required to have a fraud level below the reference fraud rate?

  • 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_4034
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

F35.00 Covered Bonds - FX rates to be applied

There are circumstances where the covered bond has been issued in one currency and the underlying assets are in a different currency. In which case, the covered bond programme would hedge this cross currency risk. In this circumstance, which FX rate should be applied? The spot FX rate as per the reporting date or the strike FX rate as per the swap agreement?

  • 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: 2015_2270
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

F35.00 Covered Bonds reporting of over collaterization

In Rows 020 and 030, Columns 220-250, are UK banks required to complete these cells if over collateralisation is determined on a nominal basis as per UK covered bond regulations?  If so, how should over collateralization be translated into Present Value (what discount rate should be applied) or how should we determine the Asset Specific Value?

  • 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: 2015_2269
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Row asset-backed securities in Asset encumbrance templates

Can you please make the row 060 'asset-backed securities' in table F 32.01 consistent with the Annex XVII (reporting on asset encumbrance) page 10 'of which: securitisations'? Same applies to row 180 in F 32.02.

  • 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: 2015_1999
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Realization of developers' collaterals and re-classification of developers into performing status

Clarifications are requested surrounding the classification of a borrower into default status and therefore into non-performing status, when the borrower is a developer / construction company and hence relies on the realisation of collaterals to repay his loans.

  • 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_3747
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of the interest income and interest expense from hedging derivatives

Our question is in which item of template F 02.00 (FINREP IFRS 9) interest income and interest expense from hedging derivatives classified in the category ”hedge accounting” should be reported, where:the hedging derivatives are used to hedge interest rate risk and are measured at fair value through profit or loss;the dirty price approach is the convention applied by the credit institution; andthe hedged instrument is not measured at fair value through profit or loss (i.e. the hedged instrument is a debt financial instrument whose interest is recognized as “interest income” or “interest expense” in the statement of profit or 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)
  • ID: 2017_3601
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Template F 16.04 line row 070 – relevance for nGAAP

In Annex IV (Financial Reporting for National GAAP based on BAD) of Commission Implementing Regulation (EU) No 680/214 in template F 16.04 excel the row line 070 ”Gains or losses on Financial assets and liabilities held for trading” is not black, while this cell is an IFRS cell. Is it an error?

  • 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: 2017_3578
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of transfer between capital surplus (share premium) and retained earnings in FINREP F 46 template.

Under the Hungarian legislation negative balance of retained earnings could be offset by a transfer from other elements of own funds. If such transaction occurs how should it be reported in template F46?

  • 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: 2017_3504
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

FINREP Template F20.04 (r210,r230)

Template F 20.04, row 210 reports ”Non-financial corporations – Of which: Loans collateralized by commercial immovable property”. However, in Hong Kong there could be non-financial corporations (NFC) borrowing loans that are collateralized solely by ”Residential immovable property” rather than by “Commercial immovable property”. For this case, should the corresponding loan amount be reported in row 230? Similarly, should household (HH) borrowing loans that are collateralized solely by ”Commercial immovable property” require to be reported in row 230, “Households – Of which: Loans collateralized by residential immovable property”?

  • 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: 2017_3486
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of securitisation instruments in FINREP templates F 04.01 – F 04.04

How should Residential Mortgage-Backed Security (RMBS) instruments be reported in FINREP templates F 04.01 – F 04.04? Which counterparty sector should the RMBS be assigned to?

  • 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: 2017_3477
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Definition of "hybrid contracts" in FINREP template F 08.01

What shall be considered a ‘hybrid contract’ for the purposes of reporting FINREP template F 08.01?

  • 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: 2017_3476
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Promise to pay and financial difficulties

If a customer misses a payment he or she can promise to pay the amount due in the same month (after we have contacted our customer). Should we define such a situation as a promise to pay or as a payment reminder? We have currently defined this situation as a promise to pay (‘Toezegging’ in Dutch), but that may diverge from the EBA perception of the associated risk with a promise to pay. As there have been several discussions on this topic with our supervisor we would appreciate EBA guidance. This should provide us with sufficient information to define this event in such a way that there can be no misinterpretations about meeting forbearance criteria.

  • 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: 2017_3463
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Disclosure of the difference between the fair value of a loan portfolio acquired/originated by a Bank and its contractual value

The fair value of a loan portfolio acquired/originated by a Bank differs from its contractual value. This difference (fair value adjustment on initial recognition (the “adjustment”)) has to be recognised in accordance with IFRS 3. In such case and since there is no separate column for this component, shall we reflect this adjustment in Template 4.4 row 170 ‘Loans and advances’ - under gross carrying amount (c010-c020) or under stock of provision (c030-c050)? We note that the issue of reporting this adjustment also arises on several templates which have no separate column for this component, namely F6, F7, F12, F20.4, F20.7, F18 and F19.

  • 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: 2017_3431
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of assets credit-impaired at purchase within template F 04.03.1 and F 04.04.1

How shall row 190 (columns 015-070) within template 4.3.1 be filled in order to fully comply with, in our interpretation, contradictory attributes stated in the terms of both rows and columns?

  • 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: 2017_3410
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Precisions on the Entity Code on COREP Solva Group (C06.02) and FINREP F40.01

Is the EBA expecting a specific relation between the column 020 in the COREP C06.02 and the column 020 of the FINREP F40.01 template ? The annexes 2 (solvency) and 5 (FINREP) of the regulation 680/2014 do not bring any information regarding an expected accordance, and only indicate that the code should be unique for each line of the template. However, those codes seem to have the same purpose, and the same entities are likely to be reported on those templates on each remittance. Therefore : - Is an entity reported in both C06.02 and F40.01 supposed to share the same code on the columns 020 of the both templates? - Is an entity reported in one of those templates supposed to share the same code in the next remittance of the template? Similar questions can be asked regarding the columns 010 of the large exposures templates (C27 to C31).

  • 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: 2017_3390
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019