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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

Validation rules v2817_m & v2823_m between the Finrep conso & AE-CON conso reportings

We have 2 validation rules v2817_m & v2823_m that can't be solved between the Finrep conso & AE-CON conso reportings.For the Debt securities sum({F 32.01, r040, (c010, c060)}) = sum({F 01.01, c010, (r080, r094, r120, r160, r173, r177, r190, r220, r232, r236)}) [v2817_m] checks the total of debt securities in the Finrep with total of debt securities reported in AE F32.01  There are additional checks on details;For Central govs:if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r070, (c010, c060)}) = {F 04.01, r080,c010} + {F 04.02, r080,c010} + {F 04.03, r080,c030} + sum({F 04.04, c060, (r030, r170)}) [v2818_m]For Financial corporations:if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r080, (c010, c060)}) = sum({F 04.01, c010, (r090-100)}) + sum({F 04.02, c010, (r090-100)}) + sum({F 04.03, c030, (r090-100)}) + sum({F 04.04, c060, (r040-050, r180-190)}) [v2819_m]For corporations:if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r090, (c010, c060)}) = {F 04.01, r110,c010} + {F 04.02, r110,c010} + {F 04.03, r110,c030} + sum({F 04.04, c060, (r060, r200)}) [v2820_m] In the Finrep report the covered bonds & asset backed securities are reported in 1 of the 3 above categories while in the Asset encumbrance tables these types of securities are part of a separate category. Those rules doesn't allow Banks to report anything in the AE for covered bonds and asset backed securities …Other assets sum({F 32.01, r120, (c010, c060)}) = sum({F 01.01, c010, (r020, r060, r092, r240-260, r290, r320-330, r360-370)}) [v2823_m] doesn't contain PPE and goodwill. Then total of assets in asset encumbrance can't be reconciled with total asset in the Finrep.  We considered the following check as a control that both amounts are more or less aligned: {F 36.01.c, r230,c180} ≡ {F 01.01, r380,c010}

  • 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: 2016_2732
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

COREP LE template C 28.00, C29.00

Where do we report deposit on demand in banks and other receivables on LE templates?Where do we report other receivables on LE templates?How should we report total exposures if exclusion of deposits on demand and other receivables causes decrease of total exposure under threshold of large exposure?

  • 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_1960
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Correct reporting in COREP Credit Risk Standardised Approach (CRSA) template of repo / SFT Positions with Cash Collateral CRM Substitution Effects

The question concerns the reporting method under the Credit Risk Standardised Approach (CRSA) of (reverse) repurchase transactions and/or securities financing transactions (SFT) which are (partly) collateralised by cash on deposit. Specifically, this concerns the correct reporting of the CRM substitution effect of cash collateral received and the allocation of a 0% risk weight of the portion of the exposure covered by such collateral.

  • 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: 2016_2693
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reported overshootings in C 24.00

How should the number of overshootings in VaR be reported in C 24.00?

  • 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: 2016_2759
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Forbearance ITS

Should we consider a loan/exposure for which the contractual terms and conditions have been modified to help a debtor to face financial difficulties as forborne if there is no loss for the bank?Is there any materiality threshold for the loss to consider forbearance?To calculate the loss (i) should the bank compare the previous terms and conditions with the new terms and conditions or (ii) should the bank compare the new terms and conditions with the current terms and conditions for a debtor with a similar risk profile?

  • 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: 2016_2826
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Template C 05.01 column 060 positive or not

In template C 05.01 we understand that all amounts in column 060 should be positive or null. In the first versions of validation rules, the rule v3693_s confirmed this interpretation. But this validation rule is deactivated from June 2014 in validation rules file. Should this column be systematically positive or not? When will you reactivate these validation rules?

  • 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_2482
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Validation rule 1740_m

Regarding validation rule v1740_m (sum({F 20.06, r010, c010, (sNNN)}) = xsum({F 08.01.a, (r010, c010, c034)}), we would like to note the following:Template F 08.01 row 010 and columns c010 & c037, should be completed by the carrying value of derivative liabilities according to recognition portfolio as hedging instruments (F 08.01.a, r010, c037) or as trading (F 08.01.a, r010, c010), by those entities which apply IAS or IFRS (please see below reference 1).Template F 08.01 row 010 and column c034, should be completed by those entities which apply National GAAP.On the basis of the above two benchmarks the relevant validation cannot apply.Furthermore, template F 20.06 according to Annex V part 2 par. 108 (please see below reference 2), should be reported the total carrying value from both portfolios, hedging or trading, country by country. It is not clear that the breakdown per counterparty sector applies only for the trading portfolio.Finally, template F 08.01 should also present deposits which are distinguished by accounting portfolio (Held for trading, Designated at fair value through profit or loss, Amortised cost). What should be the treatment of these financial instruments which are also presented in template F 20.06 (validation rule v1742_m)? Should we submit the total carrying value of the three portfolios country by country?

  • 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: 2016_2835
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Maturity Bucket of Call Deposits for Large Exposure Reporting

What is the correct maturity bucket to report call (on-demand) deposits in Large Exposure Reporting template LE4?

  • 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: 2016_2644
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Derivatives not shown in the Balance Sheet and Derivates shown as Liabilities

Are derivatives shown as assets on the balance sheet or derivatives shown in CoRep basis for template LR1?

  • 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: 2014_1267
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reference period for items reported on a cumulative basis

According to the Final Q&A 2013_619 (posted on 30/04/2014), ‘information submitted… referring to a certain period shall be reported cumulatively from the first day of the accounting year to the reference date’, ‘the FINREP templates should be reported on a cumulative basis’.However, the Final Q&A 2013_158 (posted on 14/02/2014), talking about ‘Amount of cumulative change in fair values’, says that ‘Retrospective application back to the date of initial acquisition’ or ‘to apply the requirements retrospectively from the earliest period practicable’.We also saw a reference about certain period in Annex V, Part 2, paragraph 86 of the ITS on Supervisory Reporting that made us doubt: ‘Change in fair value for the period shall include gains or losses from re-measurements of the instruments in the period’.Having these three different alternatives about reporting period’s calculation, which option would be the most appropriate to apply on ‘Amount of cumulative change in fair values’?

  • 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: 2014_1165
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Classification of institution in LR5

What should be reported in {LR5;040;1} in case of brokerage houses?

  • 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: 2014_1287
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reporting of cash collaterals included in repurchase agreements in F 08.01

In template F 08.01, repurchase agreements shall be reported in rows 100, 150, 200, 250, 300 and 350.According to the instructions (Annex V, Part 2, 91(a)) to template F 15.00, cash collaterals should be reported as repurchase agreement.There is a validation rule that partly ties the templates F 08.01 and F 15.00 together:v0912_m: {F 15.00.b, r190,c060} <= xsum({F 08.01.a, (r100, r150, r200, r250, r300, r350, c010-035)})Does it imply that cash collaterals also should be included in repurchase agreements in 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: 2014_1667
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Inconsistent validation rules of asset encumbrance templates (F 32.01, F 32.04, F 36.01)

There are several validation rules that do not appear to be appropriate:v2823_msum({F 32.01, r120, (c010, c060)}) = sum({F 01.01, c010, (r020, r060, r092, r240-260, r290, r320-330, r360-370)})According to the instructions of F 32.01 and validation rule v2814_m, if the asset encumbrance reporting is based on IFRS, then the total assets of the reporting institution (sum({F 32.01,r010,(c010,c060)})) equals to the total assets reported in {F.01.01,r380,c010}.In order to meet this requirement, v2823_m should also contain row280 and row310 of F01.01. Now these items are missing from the formula.Validation rules v2864_m and v2865_m are applicable for rows 020, 030, 050-060 of F 32.04, however row 060 is grey shadowed.In our understanding v3309_i should be applicable only for IFRS banks because {F 36.01, r230, c180} equals to sum({F 32.01, r010,(c010, c060)}) which equals to Total assets of F 01.01 only if the report is based on IFRS. Now the formula doesn’t distinguish between IFRS and non-IFRS banks.

  • 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: 2014_1671
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Validation Rule v3688_s (Blocking Rule)

The validation rule does not seem correct as the 'Adjustments to total own funds' (Template C 04.00, column 010, row 870) could also be of a negative 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_1801
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reporting of % values in LE reports

What is the correct reporting value of % in LE templates?

  • 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: 2014_1564
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Netting of Exposures arising from CIUs

Under the approach of Article 350(2) CRR, shall netting be permitted between positions in the underlying assumed investments of the CIU and other positions held by the institution, e.g. stock positions which are traded to hedge the underlying risk exposure of the CIUs?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2917
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 31/03/2017

Gross-up calls on Tier 2

Should gross-up cases on Tier 2 be allowed only in relation to coupon withholding tax (and not principal)?

  • 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: 2016_2849
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 31/03/2017

Treatment of negative accrued interests in the credit risk

Do negative accrued interests reduce the exposure value, whereas positive accrued interests increase the exposure value?In particular, are negative accrued interests deducted from CET1 and should a reduction be done, if the negative accrued interests are already included in the retained earnings, according to article 26(1)(c), or in the losses for the current financial year, according to Article 36 (1) a of 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: 2016_2795
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/03/2017

Interaction between benchmarking and additional capital requirements under Article 458 of CRR

For the benchmarking exercise for credit risk, the ITS templates request banks to report risk parameters (such as PD, LGD) and capital requirements (RWA) for the low and high default portfolio. However for some portfolios in scope of these exercises NCAs can have imposed additional capital requirements for macroprudential or systemic risk at the level of the member state (Article 458 CRR). For instance, in Belgium the NCA has imposed a 5% additional risk weight add-on (for targeting asset bubbles in the residential property sector). These RWAs relate directly to exposure in scope of the benchmarking exercise (in this example HDP template C 103.00), but under supervisory reporting the resulting RWA is not reported in C 08.01 / C 08.02 but in C 02.00 as an OTHER RISK EXPOSURE AMOUNTS (row 1.8.2). It is unclear whether additional capital requirements under Article 458 CRR, when specifically linked to a portfolio in scope of the ITS on benchmarking, should or should not be included in our submission of benchmarking templates.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2015_2377
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Clarification of columns 050 and 060 of template C 101.00, Annex I of the Benchmarking exercise.

In ITS-Annex I of the Benchmarking exercise the columns 050 and 060 provide the ISIN code and Bloomberg ticker, respectively. Is the requirement to report only exposures to the instruments specified by the ISIN/Bloomberg ticker or should all exposures to the counterparty be reported?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2892
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017