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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

Obligors for total exposures in template CR IRB 1

Should r010, c300 of template C 08.01 be additive for number of obligors e.g. a retail Customer has 3 exposures in different obligor grades, 2 are On Balance sheet and 1 is Off Balance sheet. In template C 08.02 this would be disclosed as 3 obligors given that they are included within 3 different grades. In templates C 08.01 should this customer then be disclosed as 3 obligors in r010, c300 or 1 obligor?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1540
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Asset encumbrance templates - Some cells are mapped with the same data point of other ones, but not all of them can be reported on a consolidated basis

Should be reported on a consolidated basis the cells related to F 36.01 and F 36.02 templates mapped with the same data point of the ones related to F 32.01 and F 32.02 templates, which have the coordinates specified below? In general, should columns 50 and 70 of templates F 36.01 and F 36.02 be reported on a consolidated basis?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2824
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 03/02/2017

EBA validation rule (Leverage Ratio) v4456_m

We think that the validation rule v4456_m may not be correct because the first part is deducting row 260 of C 47.00 “(-) Exposures exempted in accordance with Article 429(14) of the CRR”. However, the exposures included in C 47.00 row 260 are reported in C 43.00 row 090 “Exposures treated as sovereigns” which is added in second part of the validation rule. v4456_msum({C_47.00, c010, r[010, 020, 030, 040, 050, 060, 070, 080, 090, 100-260]}) = sum({C_43.00.a, c010, r[010, 040, 050, 060, 065, 070]}) + sum({C_43.00.b, c010, r[080, 090, 140, 180, 190, 210, 230, 280, 290]}) + sum({C_43.00.c, c020, r[080, 090, 140, 180, 190, 210, 230, 280, 290]})Should it be changed this validation rule in the following sense?sum({C_47.00, c010, r[010, 020, 030, 040, 050, 060, 070, 080, 090, 100-260]}) ≤ sum({C_43.00.a, c010, r[010, 040, 050, 060, 065, 070]}) + sum({C_43.00.b, c010, r[080, 090, 140, 180, 190, 210, 230, 280, 290]}) + sum({C_43.00.c, c020, r[080, 090, 140, 180, 190, 210, 230, 280, 290]})

  • 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_2997
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Concept of “secured liabilities”

It is unclear whether the concept of “secured liabilities” as mentioned in Article 44(2)(b) BRRD covers liabilities benefitting from a State guarantee (including thus the so-called “GGBBs”) or whether it is limited to liabilities secured by assets (collateral)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3119
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Is there a mistake in the Validation formula V4448_m and in the corresponding statement in the ITS?

Is there a mistake in the Validation formula v4448_m and in the corresponding statement in the ITS?

  • 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_2915
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting of Treasury bills (henceforth T-bills) in template F 01.01

Where should T-bills be reported in template F 01.01 – Balance Sheet Statement?

  • 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_2962
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Mutual agreement to waive the requirement to establish a European resolution college

How should the reference to “mutual agreement” with regard to waiving the requirement to establish a European resolution college stated in Article 89(4) of Directive 2014/59/EU (BRRD) be interpreted?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3024
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Legal reference to Article 39 of Regulation (EU) No 575/2013 (CRR) in row 020 ‘Deferred tax assets that do not rely on future profitability’ in template C 04.00 of Annex II of Regulation (EU) 680/2014 (ITS on supervisory reporting),.

Is the legal reference to Article 39 CRR of row 020 in template C04.00 in Annex II of ITS on supervisory reporting correct?If yes, the name of the row 020 in template C04.00 should be amended according to the headline of Art. 39 of CRR and two sub-items 1.1.1 and 1.1.2 should be introduced which cover and discern the items in para. 1 and para. 2 of this Article.If not, the legal references of row 020 in template C04.00 should refer to Art. 39 (2) of CRR, only. In addition a new row in template C04.00 (independent from item 1 ‘total deferred tax assets’ and item 2 ‘Total deferred tax liabilities’) should be added in order to capture the information of Art. 39 (1) 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: 2016_2724
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting of collective allowances for incurred but not reported losses on non-performing exposures in FINREP F 18.00 and F 19.00 templates

If incurred but not reported losses (IBNR losses) relate to a non-performing exposure, in which column should the collective allowances for IBNR losses be reported in template F 18.00 and F 19.00?

  • 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_2887
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Scope of bail-in tool regarding client assets or client money held on behalf of UCITS

Does the provision regarding the scope of bail-in tool applicable to client assets or client money held on behalf of UCITS (Article 44(2)(c)) have to be expressly transposed into national law?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3022
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Which amount should be reported in template C 22.00, column 020 and 030 - all positions?

According to Regulation 680/2014 (ITS Supervisory reporting) - Annex II , institutions should report in template C 22.00, column 020 and 030 all gross long and short positions due to assets, amounts to be received and similar items referred to CRR article 352 (1).When an institution (reporting currency EUR) enters into a foreign exchange Forward, e.g. sell USD (notional EUR 100, Present value EUR -95) and buy GBP (notional EUR 100, present value 100), which value should be reported in columns 020 and 030?Should it be:a) notional position: long GBP (EUR 100) and short USD (EUR 100)b) present value of the notional positions: long GBP (EUR 100), short USD (EUR 95)c) present value of the notional positions: long GBP (EUR 100), long USD (EUR -95)

  • 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_2900
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Rules on qualifying holdings in credit institutions

a) Do the rules on notification and assessment of proposed acquisitions of qualifying holdings apply to legal mergers between credit institutions? Is this assessment dependent on whether the merging entities belong to the same group or not?b) Can a competent authority oppose a proposed acquisition, on the basis of concerns related to financial stability. More specifically, can a competent authority oppose a proposed acquisition due to lack of agreement on Memorandums of Understanding on branch supervision between the home state of the acquiring entity and the home state of the acquired entity (which will be host state following the acquisition and future integration)?c) Can a competent authority refuse to make a decision on a proposed acquisition of a qualifying holding and thus exceed the maximum assessment period of 60 working days due to lack of agreement on Memorandums of Understanding on branch supervision between the home state of the acquiring entity and the home state of the acquired entity (which will be host state following the acquisition and future integration)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3010
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 03/02/2017

COREP C 17.00 - operational risk / losses to be reported

In COREP C 17.00, is there a definition of which losses have to be reported related to usury and compound interest? Our bank also includes losses here that are linked to credit risk (to be more specific: fraud linked to credit risk). Although fraud is indeed covered by COREP C 17.00, we understand the underlying rules of COREP C 17.00 to be "operational losses only". However, we are unsure what the correct interpretation of "operational losses" is here. For the determination of capital requirements, should these credit-risk related fraud losses be captured within the operational risk (so COREP C 17.00) or within the credit risk?

  • 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_2874
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Original Exposure Pre-Conversion factors

Should column 010 of CR SA (C 07.00), "Original Exposures Pre Conversion factors" be reported based on Secured/Unsecured part of the exposure?

  • 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_1636
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

C 41.00 - Inconsistency between Validations and EBA member/dimension types causes validation v0668_m to fail

Validation rule v0668_m states that r{r010} = sum(r020-100). We believe this validation rule will fail due to the fact that the categorisation of row 100 (x3 - 'Defaulted') for dimension Impairment status is different than the one for row 010 (x5 -'Non defaulted') which represents the total as per the validation rule.

  • 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_1466
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting of deductions of receivables assets for cash variation margin provided in derivatives transactions in LR4 (C43.00)

In which row(s) shall the receivables for cash variation margin provided in derivatives transactions be reported?

  • 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_2982
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting template C40.00 (LR1): Validation rules v0101_h and v0102_h should be amended

Should column 070 of C40.00 be exempted from the application of validation rule v0101_h and v0102_h?

  • 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_2981
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting LR2 - exposures to consider?

In Template CRD41 / LR2, shall we include or exclude derivatives and SFT's in the exposures distributed by risk weighted? The regulation is focusing on ON and OFF balance sheet items while the title of the Template mention "Total on- and off-balance sheet exposures belonging to the banking book as well as exposures of the trading book subject to counterparty credit risk (breakdown in accordance with the risk weight):".

  • 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_2945
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Inconsistency between a template and instructions regarding F 09.01

Point 61 in Part 2, Annex V of Commission Implementing Regulation (EU) No 680/2014 specifies what is included in rows "of which: defaulted" in the FINREP template 9.1 (F 09.01). However, if we look at that template, it contains rows named "of which: non-performing". Which is 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: 2016_2928
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Allocating Revaluation Reserves in F 46.00 / Difference Total Comprehensive Income in F 46.00 and F 03.00

The Total comprehensive income for the year in table F 46.00 should be equal to the Total comprehensive income for the year in table F 03.00. All tables in the FINREP should comply with IAS/IFRS. There are two validation rules to ensure this reconciliation: V1383_m (Blocking) and V1384_m (Non-Blocking) Validation rule V1384_m takes into account less items for the Total comprehensive income in F 46.00 than does validation rule V1383_m. V1384_m does not take into account Item Revaluation reserves in F 46.00, which is taken into account for the Total comprehensive income in F 03.00. How can one comply with both V1383_m and V1384_m at the same time, when both validation rules take into account different line-items?

  • 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_2911
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017