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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

ABCP Programme

Does an ABCP programme meet the definition under Article 242(9) of Regulation 575/2013 – or Article 242(11) CRR as amended by Regulation (EU) 2017/2401, which refers to-Article 2(7) in Regulation 2017/2402   when it invests not only in securitisation transactions (i.e. ABCP transaction as defined in Article 2(8) in Regulation 2017/2402) but also in other type of assets?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4324
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Validation rule on C_05.01 template - V0193_M

Should V0193_M validation rule be deactivated or changed?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4256
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Consistency of COREP validations rules e4896_n & e4895_n

Are the COREP EBA validation rules e4896_n & e4895_n consistent with Article 134 (7) of 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Clarification on what is considered insured deposits

When determining the covered deposits, should netting with customer loans be applied before determining the amount of deposits which are not covered by the DGS?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2324
  • Topic: Rights of depositors (Eligibility, coverage level, repayable amount, repayment, claim against DGS, depositor information)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Risk weights for the core indicator set

EBA/GL/2015/10 Article 58, bullet point 2 suggests that there is no flexibility of the risk weights when the core risk indicator set are applied (with no additional indicators or any indicators left out). Would it be in compliance with the guidelines to use the core indicator set but to distribute the 25 % flexible weights somewhat different than what article 58, bullet point 2 suggests?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/10 - Guidelines on methods for calculating contributions to deposit guarantee schemes
  • ID: 2017_3096
  • Topic: Funding provisions (financing means, use of funds, borrowing, calculation of contributions)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Definition of payee for dynamic linking

Article 5 of the RTS on strong customer authentication and secure communication requires the authentication code to be specific to the amount of the payment transaction and the payee.Does it suffice to include a meaningful part of the identifier into the calculation of the authentication code? For instance, would it suffice to include only numeric characters of the IBAN in the calculation of the authentication code?

  • 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: 2019_4556
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Dynamic Linking for batch payments

With regards to dynamic linking for a batch of remote electronic payments, should the authentication code be linked to each and every IBAN of all the beneficiaries in a batch file?

  • 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_4435
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Dynamic linking for batch transactions

In relation to payment transactions for a batch of remote electronic payments to one or several payees, please clarify whether the payer needs to be made aware of every payee in the batch?

  • 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_4415
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Data authentication standards

Does a non-remote card payment transaction with a secure, dynamic data authentication of the card (DDA or higher), based on ISO/IEC 7816 (for contact cards) and ISO/IEC 14443 (for contactless card) used with a static PIN meet the requirements of Article 4 of the RTS on Strong Customer Authentication (SCA)?

  • 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_4110
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Scope of ‘initiation of an electronic payment transaction’

Does a card payment transaction, authenticated with a signature at the point of sale, fall under the scope of Article 97 (I) (b) PSD2? Is there a difference if the signature is provided on a paper or on a signature pad (e.g. electronic signature pad or signature capture at a payment terminal)?

  • 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_4108
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Confidentiality of the application cryptogram for EMV transactions

Are EMV (Europay, MasterCard, Visa)  transactions (for which the application cryptogram is not enciphered during its transmission) compliant with the RTS on strong customer authentication?

  • 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_4054
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

FINREP Template F 40.01

Annex V Part II paragraph 296 (f) of Commission Implementing Regulatio (EU) No 680/2014 states of  “”Equity of Investee”, “Total assets of the Investee” and “Profit or (loss) of the Investee” include the amounts of these items in the last financial statements of the investee.” Does this refer to the latest set of financial statements of the investee which have been approved by the investee’s board of directors, or similarly authorised committee?

  • 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_2141
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Large Exposures Reporting

We are seeking clarification on how exposures to Central counterparties are to be classified for large exposures reporting. We are unclear whether these counterparties are to be reported as unregulated financial entities and reported in LE4 or other and therefore only reported in LE1 and LE2. We have exposure to the London Clearing House which is a recognised clearing house, supervised by the Bank of England.

  • 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_2086
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Template C 08.02 - Col 080 has Missing 'CRM Effects/Collateral' dimension

In template C 08.02, col 080 is defined without the dimension 'CRM Effects/Collateral [CRM]'. This looks logically incorrect and would also result in failure of validation rule: v0347_m {c090} = {c020} + {c070} + {c080}

  • 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_1464
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

ALMM - C 70.00 : Reporting on holidays and weekends of internationally active credit institutions with subsidiaries in different countries in ‘Roll-over of funding' template

How should (banking) holidays and weekends be reflected in C 70.00 (zeros, empty lines or constant volumes)? How should an internationally active credit institution with subsidiaries in different countries reflect holidays in different countries and working days in the weekend? Is there a different approach to be taken for non-maturity funding versus term funding in light of weekends and (banking) holidays?

  • 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_3689
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Committed liquidity facilities to a special purpose vehicle (SPV)

Figure 4.1.2 of ANNEX XIII clearly refers to Article 31 or Regulation (EU) 2015/61, which is the regulatory basis of the LCR. According to Article 31 committed liquidity facilities to SPVs which have a maturity date above 30 days are not considered within the Outflows. Therefore we would not consider these cash flows in row 1130. Row 1090 has no reference to Art. 31 of the LCR and it states the requirement '[...] the maximum amount that can be drawn in a given time period'. Is it correct to show above mentioned cash flows only in row 1090?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3681
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Where to include nostro current account balances that Bank of Cyprus maintains with other credit institutions in LCR-Inflows (Template 74)

Where should we include nostro current account balances that Bank of Cyprus maintains with other credit institutions in Template 74 of LCR: in line 1.1.2.2.2 monies due from financial customers or 1.1.6 monies due from assets with an undefined contractual date?

  • 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_3475
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Treatment of changes in deposit balances due to changing exchange rates in AMM template C 69.00

In the event that the original currency balance of a non-GBP deposit balance does not change from the prior reporting period reference date to the current reporting period reference date, but the GBP exchange rate changes, so that the reporting currency balance at the current reporting period reference date shows an increase on the prior period, should this increase be reported as new funds in AMM C 69.00?- Section 1.4.1 of Annex XIX referring to legal references and instructions for template ‘Prices for Various Lengths of Funding (C 69.00)’ requires ‘transaction volume and prices paid by institutions for funding obtained during the reporting period and still present at the end of the reporting period’.- It is unclear from the guidance whether upward revaluation of non-GBP funding into reporting currency from one reporting reference date to the next should be regarded as ‘funding obtained during the reporting period’.

  • 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_3370
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

C 69.00 – Spread calculation

Is the spread calculated from a daily rate or a month-end rate?

  • 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_3361
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019