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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

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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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

Difference between a reduction to zero and a cancelation

Can you explain what is the difference between a reduction to zero and a cancelation referred to in Article 63(1)(e), (g) and (h) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3557
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Powers of resolution authorities Article 63 and Article 38(1)(a)

Both Article 63 and Article 38(1)(a) of Directive 2014/59/EU (BRRD) make reference to powers of resolution authorities. How do these powers complement one another?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3556
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 10/11/2017

Notification of model changes

Does an alignment of the quantification of default to the default frequency based on an approved method (i.e. an update to the PD scale to better mirror the default frequency) require a notification? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2015_2468
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/11/2017

Deposits received and deposits posted as margin collateral for derivative exposures

Under Article 21 of Commission Delegated Regulation (EU) 2015/61: 1. Is the treatment of cash collateral received and cash collateral posted symmetrical in C73.00 and C74.00 in line with the answer given in Single Rulebook Q&A 2014_1089, which specifically referred to LCR C52.00 and C53.00? 2. Does the phrase “…collateral to be received” mean collateral already received at the reporting 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_3163
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/11/2017

Qualifying own funds included in consolidated own funds

Should an institution which has issued Additional Tier 1 (AT1) and Tier 2 (T2) instruments to external investors, and which is subject to consolidated supervision on the basis of the consolidated situation of its immediate parent financial holding company, apply the restrictions on the consolidated inclusion of AT1/T2 instruments issued by subsidiaries as provided for in Articles 82 and 85-88 of the CRR, where the parent holding company’s only assets are the shares in the institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3329
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 03/11/2017

Commitment to buy newly issued shares and synthetic holding deduction

What would be the prudential treatment applicable to a financial instrument where a bank commits itself to buy newly issued shares of an insurance company for a given amount should certain events occur?

  • 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_3292
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 03/11/2017

Section 3(a)(2) guarantees - eligibility for MREL

Can debt securities issued under a Section 3(a)(2) bank note program where the guarantor is a branch of the issuer be deemed to meet the criteria of article 45 of the BRRD in order to be included in the amount of own funds and eligible liabilities?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2966
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 27/10/2017

Sliding scale method

We would prefer to apply the "sliding scale" method mentioned in EBA/GL/2015/10, but a strict interpretation of the methodology within the guidelines prevents the use of the whole defined scale.Would it be in compliance with the Guidelines to adjust the formulas in order to achieve ARW along the whole defined scale? And what adjustment would be preferable?

  • 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_3095
  • Topic: Funding provisions (financing means, use of funds, borrowing, calculation of contributions)
  • Date of submission:
  • Published as final Q&A: 20/10/2017

Cost of living of legal persons

Do legal persons (for instance businesses like SMEs) have a “cost of living”?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2908
  • Topic: Rights of depositors (Eligibility, coverage level, repayable amount, repayment, claim against DGS, depositor information)
  • Date of submission:
  • Published as final Q&A: 20/10/2017

The question relates to systemic risk buffers and whether they can be additive

According to Article 134 CRD can two systemic risk buffers (SRBs) be additive e.g. in situations where a home country already has a SRB in place and wants to reciprocate a SRB from another Member State?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3229
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 13/10/2017