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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

Minority Interests and guidance on additional own funds (P2G)

Should the guidance on additional own funds be taken into account in the quantification of the minority interests of a subsidiary that is included in an institution`s consolidated CET1 capital according to Article 84(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3658
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Consumer mandate under Merchant Initiated Transactions

Terms and Conditions to outline future charges (under Merchant Initiated Transactions (MITs)) may be disclosed by the booking entity (such as online travel agent or brand/hotel group) instead of the hotel merchant. Does the consumer acknowledgement of these terms through a party other than the merchant (in this case, the hotel) meet the MIT requirement? Will the merchant in this situation continue to be the hotel, instead of the intermediary?

  • 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_4794
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Merchant Initiated Transactions exemption for hotel transactions

For the following scenarios, does digital acknowledgement by the consumer at time of booking that subsequent charges may be collected adequately meet the requirement for Merchant Initiated Transactions if SCA is also taken at time of booking:i. total room charges and applicable taxes disclosed to the consumer when a prepaid rate has been selected.ii. deposit amount disclosed to the consumer when the reservation requires payment of a deposit to guarantee the booked room and/or dates.iii. disclosed late cancellation or no-show fee incurred by the consumer if the consumer fails to cancel their reservation per the disclosed cancellation policy.iv. disclosed descriptions of types of charges that will be processed by the hotel merchant if incurred after payment for the stay has been settled. Examples include but are not limited to charge-to-room meals, spa treatments, retail purchases, mini-bar consumption identified by housekeeping and room damage.

  • 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_4792
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Processing payments for hotel reservations

Can hotels continue to process payments for which strong customer authentication (SCA) has not been completed at the time of reservation, or for charges which do not become apparent until after the customer has departed the hotel and for which he/she may refuse to conclude a first or additional 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: 2019_4791
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Keyed Mail Order or Telephone Order (MO-TO) transactions

In the hotel industry, if a consumer contacts the hotel directly to make a reservation, the hotel may need to manually key the payment details into their payment terminals. Does this qualify as a Mail Order or Telephone Order (MO-TO) transaction?

  • 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_4790
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Treatment of electronic bookings similar to Mail Order and Telephone Orders (MO-TO) transactions

Would hotel use-cases, which include reservations taken by third parties (such as online travel agents or brand/hotel group) for the merchant and subsequent transactions (such as post-booking processing of prepaid rates or deposits, processing of cancellation/no-show fees, processing of post-checkout charges) fall under the scope of Mail Order and Telephone Orders (MO-TO) transactions and are they therefore excluded from the strong customer authentication (SCA) requirements?

  • 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_4788
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Calculation of own funds required for payment institution in the Article 9 of Directive EU 2015/36 (PSD2) when "input funds" are credit transfers and "output funds" are direct debit

How to compute the “total amount of payment transactions executed” referred to in the calculation of “payment volume” for method B in the Article 9 of Directive EU 2015/36 (PSD2) when "input funds" on the payment account are credit transfers and "output funds" are direct debit?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4299
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 12/03/2021

LGD adjustment for massive disposals.

Article 500, first paragraph, point (c) of the Regulation (EU) 2013/575 as amended by Regulation (EU) 2019/876 provides for a 20% threshold to qualify disposal operation as “massive”. This question seeks clarification on how to compute the threshold.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4824
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Adjustment for massive disposals

Regarding the interpretation of Article 500(1) of the Regulation (EU) 2019/876 amending Regulation (EU) No 575/2013 (hereafter “Regulation (EU) No 575/2013 as amended”), do we understand it correctly that:“the average estimated LGDs for comparable exposures in default that have not been finally liquidated” should be derived by applying the estimation method for incomplete recovery processes, which is required under Article 181(1)(a) Regulation (EU) No 575/2013 and further explained in paragraphs 158 and 159 of EBA/GL/2017/16, to the disposed assets as of the date just before the disposal;“the average realised LGDs including on the basis of the losses realised due to the massive disposals” should be the average observed LGD for all disposed exposures based on the economic loss of each exposure, taking into account the disposal price as well as material discount effects and material direct and indirect costs associated with collecting on the instrument in line with Article 5(2) of Regulation (EU) No 575/2013the adjustment based on Article 500 for all disposed exposures cannot lead to an estimate of average losses for the disposed assets that is lower than the estimated LGD calculated under point (a) above?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4819
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Calculation of own funds required for payment institution in Article 9 of Directive EU 2015/36 (PSD2) when the payment institution offers acquiring services

How to compute the “total amount of payment transactions executed” referred to in the calculation of “payment volume” for method B in the Article 9 of Directive EU 2015/36 (PSD2) when the payment institution offers acquiring services?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4298
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 12/03/2021

The maturity ladder on template AE-CB (F 35.00)

Do institutions need to report the residual maturity of the cover pool assets or the residual maturity of the covered bonds the assets are backing in the maturity ladder of the Cover Pool Assets (C 150-C 200)?

  • 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_1891
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F35.00 Covered Bonds - Maturity profile of covered assets

How should the maturity profile of the covered assets be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2015_2271
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F35.00 Covered Bonds - Solo Legal Entity Split

How should we report Solo Legal Entities cases, where assets are included in the covered bond pool, but the liabilities are held on another entity's balance sheet?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2015_2272
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Asset encumbrance template F32.04 Sources of Encumbrance – Reporting, on individual basis and consolidated basis, of “Source of encumbrance” for securitisations.

What should be reported, on an individual basis and on a consolidated basis, as source of encumbrance in case of securitisations in which the securitised assets remain in the balance sheet (i.e, they have not been derecognised)? “Debts securities issued, of which: asset back securities” or “Collateralised deposits other than repurchase agreements”?

  • 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_2972
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

What considutes a fair value of encumberred and non-encumberred asset for morgages on immovable property?

We would like to clarify what constitutes a fair value for the purpopse of encumbered and non-encumbered assets which are link to morgage of immovable property. What value should be used for the reporting of the Asset encumbrance template : Market Value (MV) or Mortgage plus interest. In addition tot this, should this amount be restricted to cover the balance of the exposure at the reference date . For example an exposure with an immovable propererty MV of €1million and a mortgage plus interest €850k and a balance of account of €840k; What amount should we report as Fair Value 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: 2017_3094
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Nominal value of collateral received - not available for encumbrance

Point 16 of Annex XVII on Asset Encumbrance reporting states that "Assets are non-available for encumbrance" when they have been received as collateral and the reporting institution is not permitted to sell or re-pledge the collateral, except in the case of a default by the owner of the collateral. We understand from the above that 1. we should only report in Column 070 of AE-COL template, the collateral received from our clients up to the amounts of their actual exposure on the reporting day. 2. Question arise on the rule to follow to report the collateral per issuers type/type of securities in column 70. Example: At reporting date: Client 1 has €1,000 cash and €2,000 securities (€500 Govies, €1000 Financial Corps, €500 Non Financial Corps) in its account with our company. Both the cash and securities accounts of client 1 are flagged as pledged in favour of our company in case of client1's default. Client 1 has entered into deals exposing our Company to €1,200 (Exposure in Basel III) In the books (off balance sheet) of the company, the collateral received will amounts to €3,000 In AE report AE COL column 70, base on point 16 of Annex XVII of ITS, we understand that we should not report €3,000 since our company could only sell the collateral up to the level of Client 1 exposure, ie €1,200 + relevant margins. If this this understanding is correct and €1,200 + relevant margins should be reported, question arises on the way we should select this amount amongst the total collateral received. The implemented selection will indeed impact the content of the reporting rows 150 to 230. We could indeed pick up €500 Govies, €500 Non Financial Corps and €200 cash or €1,000 Financial Corps and €200 Non Financial Corps), any other configuration

  • 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_3512
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Partial and full write-off reporting in COREP

From the paragraph 49 of Part 2 of Annex V of the Draft ITS on Supervisory reporting and the answer to the question 2013_202 it is clear, that accumulated written-off amounts shall be reported in F 07.00 until the total extinguishment of all the institution's rights (by expiry of the statute-of-limitations period, forgiveness or other causes) or until recovery. Does the same principle hold for the COREP tables C09.01 (columns 060, 070)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1076
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Covered Bond issuance on template F35 Asset Encumbrance

Should retained bond nominals be included F35 of consolidated returns?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2017_3531
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Inclusion of Specialised Lending in CR IP Losses template

Should Specialised Lending and Speculative Immovable Property Financing exposures be reported in the CR IP Losses template?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1177
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting RMBS issued by SSPEs in C51.

Can the EBA confirm that our understanding is that RMBS that according to Basel III are classified as Level 2B assets and are CB eligble should be reported in C51. ID 1.11.1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2014_1041
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021