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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

Liquidity: Market value of assets and payments due on liquid assets not reflected in the market value of the asset

Which value is to be reported for liquid assets, the clean price or the dirty price? (CRR Articles 418(1) and 425(7))

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2013_154
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 30/04/2014

Applicable mappings before entry into force of ITS on Articles 136(1) and 270

What mappings will be applicable between the first date of application of Regulation No. 575/2013 (i.e. 1 January 2014) and the entry into force of the ITS on Articles 136(1) and 270?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_737
  • Topic: External Credit Assessment Institutions (ECAI)
  • Date of submission:
  • Published as final Q&A: 25/04/2014

Continuation of current liquidity waivers

Clarification is needed as to the interim arrangements pending the introduction of the waiver/group treatments provided for under Article 8 of Regulation (EU) No. 575/2013 (CRR).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_270
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 25/04/2014

Table 14 - Fair Value Hierarchy

Warum sind die Felder in Bezug auf AfS Instrumente bei den Accumulated change in fair value before taxes nicht ausgegraut ? Wenn kein change in fair value for the period angegeben werden kann, da sich dieser gem. ITS Part 2.86 lediglich auf die Gewinne und Verluste der Bank bezieht, ist entsprechend ein Ausweis des kumulierten change in fair value für AfS Positionen u.E. nicht sachgerecht.

  • 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: 2013_595
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/04/2014

Alternative calculation of own funds requirement for exposures to a Qualifying Central Counterparty (QCCP)

In the formula given in Article 310 of Regulation (EU) No 575/2013 (CRR) the trade exposure is referenced. According to article 306(1)(c) CRR and Article 306(2) CRR exemptions for the calculation of trade exposure exist, e.g. trade exposure can be set to zero under certain circumstance given in Article 306 CRR. Do these exemptions also hold when using Article 310 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_69
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 16/04/2014

Reporting of exposures lower than 300 million EUR

In the final draft ITS on reporting, chapter 3 articles 9.2 (g) and 11.2(g), it says that institutions shall submit the information as specified in Annex VIII according to the instructions in Annex IX related to exposures not considered large exposures in accordance with Article 392 of the CRR, which have an exposure value larger than 300 million EUR. We interpret this as (smaller) institutions shall report large exposures (10%), but not the 20 largest exposures and other exposures, if they do not exceed the exposure value of 300 million EUR. Have we interpreted the reporting rules for smaller institutions 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: 2013_585
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Large Exposures – Disclosure of counterparty names

Where the credit institution does not have consent to disclose the clients names, what should it report here?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_672
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Application of Article 199(6)(c) and (d) in the event that the credit institution has not liquidated any such collateral in the past

In the event that a credit institution has not liquidated the collateral referred to in Article 199(6) in the past, is it sufficient to demonstrate the availability of processes and data collection/analyses tool which enables the institution to show that the realised proceeds from the collateral are not below 70% of the collateral value in more than 10% of all liquidations for a given type of collateral in case collateral is liquidated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_669
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Exposure for Large Exposure Reporting - Accrued interests

Article 389 of the CRR states that for Large Exposure Reporting, the exposure should be identical to those in the standardised approach (Part II, Title 2, Chapter II) just without applying risk weights. According to Standard Approach for assets the risk position is defined by the balance sheet value including accrued interest and impairments being deducted. Can you confirm that this is also the definition for Large Exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_638
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

LE1 column 030 ('LEI code')

What does the legal entity identifier exactly mean? Does it mean LEI applicable in the reporting country?

  • 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: 2013_582
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Inclusion of indirect holdings in the large exposures regime

Do indirect holdings have to be included in the large exposure regime based on Article 389 of Regulation (EU) No. 575/2013 (CRR) if they are held against a financial sector entity (that is fulfil the definition in Article 36 (1)(h) or (i) of the CRR), but are not deducted from own funds and instead risk weighted according to Articles 48(4), 46(4) or 49(4) of the CRR? If the answer is yes, can the financial sector entity being regarded as the relevant client for large exposure purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_624
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Determination of clearing threshold of non-financial counterparties

Who decides if a non-financial counterparty exceeds a clearing threshold and therefore has to be included in the CVA calculation? Is this the responsibility of the counterparty? Is this only relevant for counterparties in third countries or also for counterparties in member states?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_472
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Discounts on balance sheet exposures purchased when not in default

In Regulation (EU) No 575/2013 (CRR) Article 159 it states: "......Discounts on balance sheet exposures purchased when in default in accordance with Article 166(1) shall be treated in the same manner as specific credit risk adjustments." In respect of this how should one treat discounts on purchased exposures that were not in default at the time of purchase and discounts that were not calculated on single exposure level, but instead calculated on a whole portfolio of exposures which are not in default.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_354
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Reporting requirement of the “10 largest exposures to institutions” and “10 largest exposures to unregulated financial sector entities”

How should we understand that reporting requirement?

  • 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: 2013_572
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Liquidity: Reporting on liquid assets Annexe XII; C51.00

Let's take a French bank that have an LCR >100% with a liquidity buffer composed by German government bonds. For report C 51.00 (liquidity buffer) the German government bonds should be reported only to 1 of the 6 reporting blocs. As a consequence, German government bonds will be reported in line 340 since they are of extremely high liquidity and of high credit quality. Nothing will be reported into line 440 neither 040. Is that what you expect?

  • 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: 2013_114
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Application of transitional provisions to Additional Tier 1 and to Tier 2 instruments with an incentive to redeem

When all the call options from an AT1 (or T2) instrument which has an incentive to redeem occur during the period that an institution is under state aid and, thus, subject to a ban on exercising call options on own funds instruments, should the AT1 (or T2) instrument be subject to the provisions of Article 489(5) (or 490(5) of Regulation (EU) No 575/2013 (CRR) assuming that the effective maturity date, as defined in Article 491, is the first call date after the referred ban has been removed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_590
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 04/04/2014

Definition of a retail deposit

According to Article 411(2) of Regulation (EU) No 575/2013 (CRR) a retail deposit means:- a liability to a natural person or to an SME, where the natural person or the SME would qualify for the retail exposure class under SA or IRB approaches; or- a liability to a company which is eligible for the treatment set out in Article 153(4).(plus the limit of 1 million EUR for deposits by enterprisesthat SME or company on a group basis).Article 153(4) relates to the treatment (the correlation formula) of the exposures to companies with the total annual sales (on a consolidated basis) less than 50 million EUR under the IRB approach.Do the criteria from Article 411(2) which relates to Article 153(4) mean that:- only institutions using the IRB approach and the above mentioned treatment in Article 153(4) can treat deposits from companies with the total annual sales (on a consolidated basis) less than 50 million EUR as retail deposit, or- all institutions, regardless of the approach implemented (SA or IRB), can treat deposits from companies with the total annual sales (on a consolidated basis) less than 50 million EUR as retail deposit?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_578
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 04/04/2014

Effective date of Part 8 of CRR – Disclosure by Institutions

We would appreciate clarification of the date(s) by which we are required to meet the disclosure requirements detailed in Part 8 of CRR – Disclosure by Institutions. We note disclosure is to be made on the date of publication of the firm’s financial statement, the year end for our firm is not the calendar year end but 31 March. The first year end, after the date CRR comes into force will be 31 March 2014. The disclosures detailed in Part 8 of CRR are dependent on associated EBA guidelines and draft implementing and regulatory technical standards with publication/submission dates ranging from 31 December 2014 to 1 January 2016.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_515
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 04/04/2014

Cash Inflows with symmetrical weights

In Article 425(2)(e) of Regulation (EU) No 575/2013 (CRR) it states: "Monies due that the institution owing those monies treats in accordance with Article 422(3) and (4), shall be multiplied by a corresponding symmetrical inflow." Does this mean that assets stemming from cash management, clearing and custody services have to be treated with 5% and 25% factors, in case those factors are also applied to the corresponding deposits?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_486
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 04/04/2014