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List of Q&A's

Retention bonus

Can an institution award retention bonuses to the management board in case of an intended IPO?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2017_3589
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 25/05/2018

IFRS 9 transitional provisions – Calculation of the increased amount of risk-weighted assets (RWA) in the standardised approach

Should the RWA correction (also with regard to the presentation in the Corep template 5.1) according the details in the background be calculated as follows: total amount of provisions multiplied by the scaling factor and then finally weighted by the risk weightings for each of the exposures for which these provisions were calculated? ***Muß nun die RWA-Korrektur (auch in Hinblick auf die Darstellung im Corep Template 5.1.) wie folgt berechnet werden: Gesamtbetrag der Risikovorsorgen multipliziert um den Faktor und schlussendlich versehen mit den jeweiligen finalen Risikogewichten jener Exposures, für die diese Risikovorsorgen gebildet wurden?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3664
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 25/05/2018

Wholesale Deposits regarding Deposit Insurance Scheme

How can the meaning of “liabilities” in context of Article 28(1) Delegated Regulation (EU) 2015/61 (DR) be interpreted? Does it refer to the total deposit amount from relevant clients which can be multiplied with 20% up to the deposit guarantee scheme limit (d.i.s.l.) and the rest with 40% or shall a deposit with an amount exceeding the d.i.s.l be multiplied as a whole with 40% (i.e. no dividing in 20%- and 40%-Run-Off)?

  • 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: 2017_3357
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 25/05/2018

COREP template C13: Consistency of the control v0530_m

COREP template C13: Is the EBA taxonomy control v0530_m consistent when tranches are deducted from own funds?

  • 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_3724
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

EBA COREP Validation Rules on C 05.01

Row 140 column 060 is required to have a value that is less than or equal to zero. That is specified by validation rule v5016_s. In addition, the value in row 140 column 060 includes data entered into row 380 col 060. Were the value in the latter cell entered as a large positive, it is possible that the resulting figure in row 140 column 060 would be positive. Should there be a constraint placed on the value in row 380 column 060?

  • 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_3709
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Validation rule v4792_m, C 12.00 - Securitisations

In C 12.00.a, the validation rule v4792_m is (r030;040;050;060;070;080;090)] {{c050}} <= {{c010}} Since row 30 (ORIGINATOR: TOTAL EXPOSURES) represents the totals for Originators, the above might not hold true in cases where significant early amortization exposures are present. This is because the row 100 for early amortization is greyed out for the columns 010 to 040 in the report template and hence is not considered in row 030 for these columns. However, row 100 is not greyed out for the column 050 where the validation check is applied.

  • 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_3705
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Annexes I & II, C 18.00, validation rules v4850_m and v4851_m.

Is there an error in the validation rules v4850_m and v4851_m applicable to template C 18.00? 

  • 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: 2018_3682
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

CET1 Instruments

May a CET1 instrument rank pari passu in liquidation with a legacy Tier 1 instrument that is being grandfathered as Additional Tier 1 under Article 484, and otherwise qualifies as Tier 2 under the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3521
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Definition of “Paid-Up” according to Article 28(1)(b) CRR

May contributions in kind be qualified as “payment” according to Article 28 para 1 lit b CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3636
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Scope of application of the exemption from the cap on inflows in the Liquidity Coverage Ratio

Is it legally possible for a liquidity sub-group (as per Article 8 CRR) to apply for an increase in the cap on inflows from 75% to 90% (in accordance with Article 33(4) and Article 33(5) of LCR Commission Delegated Regulation (EU) 2015/61) only for the cash inflows generated by one institution in the liquidity sub-group?

  • 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: 2017_3598
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Subsidiary repurchasing AT1 or Tier 2 instruments before five years from the date of issuance

1/ Could an institution’s subsidiary subject to prudential supervision purchase Additional Tier 1 or Tier 2 instruments issued by the institution before five years from the date of issuance of the instruments, given that this purchase would lead to a disqualification of the instruments?2/ Could an institution’s subsidiary not subject to prudential supervision purchase Additional Tier 1 or Tier 2 instruments issued by the institution before five years from the date of issuance of the instruments, given that this purchase would lead to a disqualification of the instruments?

  • 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: 2017_3587
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Market making

1. Should short positions in own AT1 and/or T2 instruments be taken into account in the calculation of the used part of the predetermined amount for market making purposes Article 78(1) last subparagraph Regulation (EU) No 575/2013 (CRR)?2. Should short positions in own AT1 and/or T2 instruments have an impact on the amount to be deducted pursuant to Article 28 Commission delegated regulation 241/2014 and EBA Q&A 1352 [as originally published on 8 July 2014]?

  • 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: 2017_3568
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Deposits with higher outflows

Does the Article 7 of Part 2 (Title II) of the EBA Guidelines on retail deposits subject to different outflows for the purposes of liquidity reporting (risk factor "maturing fixed-term or notice period") also relate to the savings accounts and transactional sight accounts with no legal maturity or is this article targeting mainly term deposits and other term products with contractual notice period? If yes, does it mean that the part of deposits under Deposit Guarantee Scheme (Article 421(1) of Regulation (EU) No. 575/2013) from clients having more than 100.000 EUR is also subject to higher outflows of more than 10%, as the deposit has 2 risk factors (high value deposit and deposit with notice period?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_912
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Definition of retail deposits with higher outflow rate

What is the definition of the condition for retail deposit with higher outflow rate: "the rate significantly exceeds the average rate for similar retail products"? Bucketing our retail deposits we have a two-fold problem with defining when deposit rate on our product significantly exceeds or does not exceed the average rate for similar retail product.

  • 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: 2015_2303
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/04/2018

Reporting of impact of adoption of IFRS 9 in F 12.01

How shall the impact of the adoption of IFRS 9 be reported in template F 12.01 “Movements in allowances and provisions for credit losses”?

  • 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_3624
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/04/2018

Credit claims in liquidity stress test buffer

Are credit claims eligible for the liquidity buffer (counterbalancing capacity) if they are not already pledged with the central bank? In particular, would the credit claims originally intended for covered bonds form part of the bank’s pool of collateral for monetary policy credit operations before they become eligible for the counterbalancing capacity (CBC)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2003
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as final Q&A: 13/04/2018

Transposition of Article 96

Should the national provisions which are going to transpose Article 96 only provide for the resolution of branches of a third-country institution located in the same Member State?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3757
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Validation Error arising from Guidance Notes for C 18.00 report

Which one should take precedence:(1) the general remarks for template C 18.00 in the ITS on Supervisory Reporting (Annex II), or(2) the existing formatting for the currency sheets of template C 18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3718
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Validation rule v_1044_m (FINREP template 16.3 IFRS9)

The validation rule v1044_m requires that for template F 16.03 the following condition is fulfilled: {r090} = sum(r010-080).However, in taxonomy v2.7 template F 16.03 has been amended: row 015 (of which: Economic hedges with use of the fair value option) has been added. Is the validation rule v1044_m still valid?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3692
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/04/2018