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List of Q&A's

Presentation of IRB floor (Article 500 CRR) in COREP templates

How should an IRB institution present Basel I floor as defined in Art. 500 CRR (an additional IRB floor requirement) in COREP reports?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3228
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 24/11/2017

Reporting of credit risk adjustments according to Article 110 of CRR

In relation to SA General credit risk adjustments, as per template C 01.00, row 920, column 010, is an institution also required to report the respective values in column 050 in template C 09.01?Furthermore, should this credit risk adjustment apply for a bank and the bank is not including it in its Tier 2 capital, is the NCA obliged to inform the bank accordingly?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3343
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 24/11/2017

LRCalc – Reporting of SFT Exposures according to Article 429 (5) (d), 429 (8) and 429b (1) CRR

Please clarify regarding securities included in Repo transactions. As per the guidelines for Row010 in LRCALC table, ‘cash received or security that is provided to a counterparty via the aforesaid mentioned transactions and is retained on the balance sheet...’ are to be reported in other assets in Row190.From the above, as cash received or security provided on balance are to be reported in Row190, these are not reported in Row 010.[1] However, for purpose of cash receivable and cash payable netting, cash received which is reported in Row190 is included for the purpose of netting which is reported in Row 010. Is there no contradiction in guidelines?As an example if an institution has done a repo transaction of own security (on balance sheet) of value 1025 and receives a cash of 1000, in Row190, 2025 is to be reported.In Row010, for purpose of cash receivable and payable netting, cash received 1000 is included in netting.Is this not double reporting?[2] In Row 020, ADD-ON for SFT transactions is to be reported as per Article 429b (1).As securities which are included in repo transactions and which are on balance sheet, full value of security is reported in Row190 as other asset, whether ADD-ON is to be calculated and reported for such securities?

  • 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_2233
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 24/11/2017

Connected Clients and Control Relationship

Is the relation between a company and its directors as they are indicated in the company’s structure (irrespective of their number and irrespective if they are executive or non-executive directors) an indicator of control? Would it thus lead to identify a "single risk" and therefore to the creation of a group of connected clients? ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2923
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 24/11/2017

Groups of connected clients when a client is connected through various criteria (interconnection through control and / or economic interconnection)

As defined in Article 4(1)(39) of Regulation (EU) No 575/2013 (CRR), clients can be included into ‘groups of connected clients’ through criteria of control (Article 4(1)(39)(a)) or economic interconnection (Article 4(1)(39)(b)).What is the correct treatment of exposure to a client in case when the client is connected with other natural or legal persons through criteria of control and / or economic interconnection?Should the institution include and report all those clients connected with particular client as one ‘group of connected clients’ regardless of criteria of connection (control vs. economic interconnection) or should the institution include and report particular client in two (or more) groups where one group includes clients that are connected with particular client through criteria of control and the other separate group (or more groups) is formed of clients that are connected with particular client through criteria of economic interconnection?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1443
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 24/11/2017

O-SII Buffer on individual and consolidated level

Article 131(5) of the CRD (Directive 2013/36/EU) states that “the competent authority or designated authority may require each O-SII, on a consolidated or sub-consolidated or individual basis, as applicable, to maintain an O-SII buffer..”. May the competent authority or designated authority also require a single O-SII to maintain an O-SII buffer both on a consolidated AND individual basis?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/10 - Guidelines on criteria to identify other systemically important institutions (O-SIIs)
  • ID: 2017_3342
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Inconsistency in validation rule v5016_s for C 05.01

Is validation rule v5016_s consistent for rows 130 and 136 of the C 05.01?

  • 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_3516
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

International Organisations allocated to the 'Institutions' exposure class

Could you please advise based on which criteria are International Organizations allocated to the “Institutions” exposure class under IRB Approach.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3479
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Validation rule e4901_n

Validation rule e4901_n (active as from DPM 2.6.0) states the following: [C 07.00.a (r140-170;190;210;220;250-280, c010-040;150-240, s014)] {C 07.00.a} = empty.We have values reported in C 07.00, s014, r140 relating to unsettled securities trades for which the contractual settlement date has not yet passed. As far as we are aware these trades do not attract a capital charge and we are reporting in on this line so as to show the exposure. Should these fields be left empty?

  • 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_3466
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Foreign Exchange Risk– Off-balance sheet items in C 22.00

What should be included in row 110 “Off-balance sheet items” of template C 22.00 (MKR SA FX)?

  • 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_3437
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Reporting requirements for template C 33.00

How shall exposures to entities that are classified differently between different reporting frameworks (i.e. FINREP and COREP) be assigned to an exposure class in Template C33?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3424
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Validations between F 13.01 and F 05.00

Are validation rules v1076_m, v1079_m, v1082_m and v1085_m correct and applicable in all cases?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 625/2014 - RTS on requirements for investor, sponsor, original lenders and originator institutions of transferred credit risk exposures
  • ID: 2017_3379
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

EBA validations rules for 2.5 with reference v2708_m and v3091_ m

In accordance with Annex V.Part 2, paragraph 162 the sum of the amounts reported for both collateral and financial guarantees shall be capped at the carrying amount of the related exposure. Does the carrying amount of the related exposure refer to the gross carrying amount of the related exposure (before accumulated provisions) or to the net carrying amount (after provisions).

  • 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_3377
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

FINREP IFRS 9, F 16.01 - Interest income and expenses by instrument and counterparty sector

Under national GAAP based on BAD, do ‘impaired assets’ consist of assets subject to specific and general impairment allowances or only those subject to specific impairment allowances? What scope of ‘impaired assets’ shall be considered for row 280 (‘of which: interest-income on credit impaired financial assets’) of template F 16.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2017_3369
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Validation rules v4764_m, v4765_m, v4766_m, v4767_m and v4768_m in template C 08.01

Are validation rules v4764_m - v4768_m correct?

  • 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_3350
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

v4760_m & v4761_m in C 02.00 and C 08.01

Are validation rules v4760_m & v4761_m correct?

  • 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_3347
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Grandfathering of own funds instruments

For application of the grandfathering rules defined in Article 484 CRR and following, does the change in debtor resulting from a merger means that a new capital instrument has been issued and that its eligibility for grandfathering or for full eligibility as an own fund instrument should be assessed at the date of the merger or should one use the initial characteristics of the bond?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3299
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 17/11/2017

On-site inspections by resolution authorities

Does Article 63(1)(a) enable resolution authorities to carry out on-site inspections to gather relevant information?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3572
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Difference between taking control and being able to exercise the control

What is the difference between taking control over the institution and being able to exercise the control?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3571
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Reference to Article 49 in Article 63(1)(k)

Is the reference to Article 49 in Article 63(1)(k) only related to the close out and termination of derivatives? Is the power to close out and terminate financial contracts valid for the purposes of applying all the Directive and not only Article 49?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3558
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017