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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

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

Rollover of Funding

Treatment of Current Accounts that have available limit being utilised: Example 1 Suppose i have a current account with opening current credit balance of EUR 100 and available limit of 150 on day 1. This account will show as a current account deposit for the rollover of funding report. Assume that the owner withdraws EUR 150 during the day. Therefore, at the end of the day it has a debit balance of EUR 50. If this is the only account the bank has, how will it show in the rollover of funding? Example 2 Suppose i have a current account with opening current debit balance of EUR 70 since it utilises its limit on day 1. This account will not show in my deposits in the rollover of funding report. Assume that the owner deposits EUR 100 during the day. Therefore, at the end of the day it has a credit balance of EUR 30. If this is the only account the bank has, how will it show in the rollover of funding?

  • 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_2700
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Two validation rules on "Treasury shares" no more available considering the cancellation of another validation rule on the same matter

Why validation rules  v2060_s (for FINREP F01.03, rows 240,260, col 010) and v2061_s (for FINREP F17.03, rows 340,360, col 010), asking for negative value are still active while the n° v2028_s (for FINREP F46.00, rows 010,040,210, col 090,110), for same value as the 2 precedent controls, asking for negative value too, has been deleted in the version 2.3

  • 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_2573
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Consistency between validation rule V3933 and paragraph IAS39 - 89A

Could you explicit the reasons of the validation rule V3933, taking account of paragraph IAS39 - 89A, mentioned in the template?

  • 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_2215
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP - Contents of template F 40.1 Group structure "entity-by-entity" - Col 160 "Carrying amount" should be higher than 0

Template F40.01 requires carrying amount higher than 0. As a principle of consolidation, enterprises over which the Group exercises significant influence (associates) are accounted for by the equity method. If the Group’BNP Paribas'share of losses of an equity-method entity equals or exceeds the carrying amount of its investment in this entity, the Group discontinues including its share of further losses. The investment is reported at nil value ans respect in this case the control in FINREP template 40.1 concerning the carrying amount. But the Group BNP Paribas consolidated also controlled but non material entities under equity method. In these cases the carrying amount is not reported at nil, due to the fact that the Group is fully involved in the entity. Is it possible to modifiy the control to authorize negative carrying amount under the condition that a comment is reported in a dedicated cell?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 530/2014 - RTS on materiality of thresholds for internal approaches to specific risk in the trading book
  • ID: 2015_2170
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP – Non-performing probation period start date on forborne exposures

Clarification is requested surrounding non-performing probation periods where forbearance precedes classification of non-performance. Scenario 1) T0 - A customer’s performing exposure has a concession event applied and is classified as performing forborne and begins the 2 year performing assessment. 2) T1 - At a later date the customer becomes non-performing through criteria in paragraph 145 (e.g. “material exposures which are more than 90 days past-due”) (not by paragraph 179 as deemed not applicable in Q&A 2014_736) and is classified as non-performing forborne. 3) T2 – Customer exits non-performing criteria. In the above scenario at which point would non-performing probation period start from? a) The non-performing probation period starts from T0, the date of where the forbearance measure is extended. i.e. Probation starts from before the exposure is classified as non-performing; b) Non-performing probation period starts from T1; c) Non-performing probation period starts from T2; or d) There is no non-performing probation period which contradicts Q&A 2014_735. It has been confirmed by the EBA in Q&A 2014_735 that a non-performing probation period is required in the scenario.

  • 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_2146
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019