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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.

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List of Q&A's

Traitement des dettes subordonnées dans l'état C 68.00 et C 67.00 (Treatment of subordinated debt in templates C 68.00 and C 67.00)

Original questionPouvez-vous nous préciser le traitement à suivre concernant les dettes subordonnées dans l’état C 68.00 (financement par produit)? Translated questionCould you please clarify the applicable treatment for subordinated debt in template C 68.00 (Concentration of funding by product type)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3139
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/03/2018

Eligible asset classification for counterbalancing capacity C 71.00 – Concentration of Counterbalancing capacity by issuer / counterparty

Should items such assenior bonds and deposits on current accounts with other credit institutions orshares of UCITS, which qualify as Liquid Assets for the LCR-Reportingbe reported in template C 71.00 – Concentration of Counterbalancing capacity by issuer/counterparty?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2897
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/03/2018

Conditions for Early intervention

What are the conditions for Early intervention in Article 27(1) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3696
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 09/03/2018

Calculation of original and residual maturities in the context of ALMM (C 66.01) for puttable bonds

Assume the following data for a puttable bond:Origination date:                               30.08.2018First investors’ put optionality:          15.02.2019Second investors’ put optionality:     15.05.2019Final maturity:                                   30.10.2020From our point of view, the instructions of annex XXII (reference 1.1.4) and annex XXIII (paragraph 12) in combination with the answers to the question 2 in EBA/ITS/2017/01 suggest this bond should be assigned with original (OM) and residual maturities (RM), both in days, for illustrative reporting dates as shown below:Reporting date: 31.08.2018: OM 169; RM 168Reporting date: 30.09.2018: OM 169; RM 138Reporting date: 30.12.2018: OM 169; RM 47Reporting date: 31.03.2019: OM 169; RM 45Reporting date: 30.06.2019: OM 169; RM 488Reporting date: 30.09.2019: OM 169; RM 396

  • 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_3287
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Treatment of Credit Unions in C 68.00 ALMM Reporting

How should Credit Unions be classified for ALMM reporting? 

  • 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_3254
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Reported currency by issuer/counterparty on a total level (in the Total sheet)

How should assets that are issued or liquidity lines that are granted by a single issuer / counterparty be reported in the Total sheet, provided that the asset received or undrawn committed liquidity lines granted to the institution are denominated in more than one currency? Should the issuer / counterparty be reported on separate lines for separate currencies, or should the currency in which the largest proportion of assets / liquidity was obtained be reported for the aggregated currencies? 

  • 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_2974
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Can the same issuer / counterparty appear more than once in the top 10 of template C 71.00 based on currency?

The ITS states firms should report the name of the top ten issuers/counterparties of unencumbered assets or undrawn committed liquidity lines granted to the institution shall be recorded in column 010 in a descending fashion. The ITS also requires a currency to be assigned to the Issuers/counterparties. If you hold assets from a counterparty that are issued in different currencies do you report the counterparty more than once? Or do you report the currency of the largest proportion of the total.

  • 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_2741
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Concentration of funding by counterparty (C 67.00) ranking

C 67.00 (Concentration of funding by counterparty): Shall we compute/report the top 10 counterparties for each currency, or is the currency irrelevant to compute this rank?If the currency is irrelevant, the top 10 counterparties would be the same list across all significant currencies sheets, with some empty results/rows for counterparties not concerned by all significant currencies.C 68.00 (concentration of funding by product): The regulation clearly states that the currency is irrelevant for product types determination above the 1% threshold (Annex 4 XIX, chapter 1.3, paragraph 4). Does this mean also that the list of products concerned is the same list across all significant currencies sheets?C 67.00 / C 68.00: If we want to keep consistency between reports C 67.00 and C 68.00, shall we apply the same principle: currency is irrelevant for ranking or sorting?

  • 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_2033
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Deduction requirements in accordance with Article 36(1) (f), (h) and (i) CRR: Netting of long and short positions in intermediate entities in the context of Article 15e (7) of Delegated Regulation (EU) No 241/2014 (“RTS Own Funds”)

Can an institution, in applying Article 15e (7) of Delegated Regulation (EU) No 241/2014 for the purpose of fulfilling the deduction requirements in accordance with Article 36(1) (f), (h) and (i) CRR – provided that all the conditions of Article 42 CRR are met - net long positions in an intermediate entity (such as an ETF) with corresponding short positions? 

  • 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_3543
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 02/03/2018

CIU Correlation Test

When applying the correlation test outlined in Article 350(2b) to a given CIU position in order to determine the appropriate capital treatment for position risk, may an institution adjust the historical prices of the CIU to reflect solely those price movements which relate to the position risk of that CIU?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3538
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Reference to Chapter III in Article 96(3)(b)

Is the reference to Chapter III in Article 96(3)(b) correct?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3703
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Enforce a third country resolution proceeding

How should the outcome under Article 94(4)(d) be achieved and in what way is that article different from the provision under Article 68?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3702
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Clarification on the authority responsible for the DGS

Which exactly is the authority responsible for the DGS referred to in Article 88?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3701
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Other groups or colleges in Articles 88(6) and 89(4)

Could you please explain what “other groups or colleges” can carry out the work assigned to the resolution colleges with regard to Articles 88(6) and 89(4)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3700
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Intervention of the resolution fund to cover for losses due to creditors / liabilities excluded from bail-in

Can Article 101(2) of Directive 2014/59/EU (BRRD) be interpreted in the way that even if all bail-inable creditors have been subjected to bail-in and losses are still not covered, a bridge bank would not be allowed to take on the remaining losses and thus resolution would not be possible?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3699
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Valuation in Article 36

How should the resolution authority perform the valuation mentioned in Article 36 of Directive 2014/59/EU (BRRD) before making the decision initiating resolution if it is not entitled to require certain information from the particular entity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3697
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Treatment of cash provided as a collateral under issued guarantees and letters of credit

Should cash provided as a collateral under issued guarantees and letters of credit be included for the calculation of the total expected cash outflows under the LCR according to CRR Articles 421(1)a, 421(5)(a) or 422(2)(a)? If included, then should this collateral be treated as retail term deposits (term is being considered as the expiry of the issued L/C)? What outflow rate should be applied for such deposits?

  • 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: 2016_2828
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Reference to value in Article 48(2)

Does the reference to “value” in Article 48(2) refer to the “face value” (“notional amount”) or to the “market value”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3629
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 26/01/2018

Calculation of general risk capital requirement for underwriting commitment regarding bond issuance and bond issuance programs under duration-based method specified in Article 340 of the CRR.

How should the capital requirement under duration-based calculation of general risk specified in Article 340 CRR be calculated where an institution is acting as an underwriter in bond issuance or bond issuance program? In particular, how to calculate the capital requirement before fixing of the coupon rate for bonds being issued and after that date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3450
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 19/01/2018