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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

Timely payment requirement for unfunded credit protection provided under credit risk insurance policies

Does unfunded credit protection - which a bank has purchased in order to hedge a loan exposure and which provides the protection-seller with the contractual right to compensate credit losses according to the original scheduled payment dates of the hedged loan - fulfil the timely payment requirement for unfunded credit protection in a situation where the loan becomes due and payable prior to the original scheduled payment dates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3576
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU as off-balance sheet exposures

Are the binding proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU off-balance sheet exposures according to Annex I CRR?Should FINREP,COREP reporting include such binding proposals for mortgage credit extension?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3376
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)

What is the correct interpretation of instrument No.40?

  • 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: 2018_4428
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Supervisory Benchmarking - Alternative risk weight

How shall mortgage portfolios for which - based on Art. 230 (3) CRR when the conditions of Art. 199 (6) CRR are satisfied - an alternative risk weight (e.g. 50% for commercial real estate) is used, be reported in the benchmarking exercise. Or should these exposures where no PD or LGD estimation is available for regulatory purposes be exempted from the reporting.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3222
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Annex I Template C101.00 - Sovereigns

Clarifications around which entities to include for those identified by a bloomberg ticker referencing a Sovereign

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3197
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Supervisory Benchmarking Exercise, Annex II, C 102, columns 070 and 080 Counterparty types

What counterparty types should be included in the Low Default Portfolio exercise?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3191
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Synthetic securitisation of undrawn revolving credit facilities

In a synthetic securitisation of undrawn revolving credit facilities (“RCF”), which is compliant with Article 245 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2017/2401, what is the EAD that should be considered inside the securitisation (which will subject to the risk weighting according to the securitisation framework) and what is the EAD that should be considered outside the securitisation (which will continue to be risk weighted according to the approved IRB model for such exposures)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4025
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 19/07/2019

Interaction between Articles 473a and 127 of the CRR (risk weight factor for exposures in default under the standardised approach)

Do banks in order to calculate the thresholds of Article 127 of Regulation (EU) No 575/2013 (CRR) have to consider all IFRS 9 provisions (without applying any scaling factor) or the amount of IFRS 9 provisions reduced by applying the scaling factor as per Article 473a?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3931
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 19/07/2019

Asset denominated in one currency and funded in a different currency subject to a FX Swap exchanging those two currencies

For the purpose of the credit risk standard risk-weight attribution, can we consider that 1) an asset denominated in one currency and funded in a different currency subject to a FX Swap exchanging those two currencies is equivalent to 2) an asset denominated and funded in the same currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3832
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/07/2019

Liability for fraud when SCA exemption used

Who is liable for fraud on Strong Customer Authentication (SCA) exempted transactions? Which payment service provider (PSP) is liable (payer’s or payee’s) when both PSPs choose to trigger an exemption to SCA?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4042
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/07/2019

Confidentiality of offline PIN

Should the PIN transmitted offline from a terminal to an Europay, MasterCard and Visa (EMV) card always be enciphered? 

  • 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_4055
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/07/2019

Responsibility for comprehensive assessment according to Article 95(2) PSD2

It is not clear, whether comprehensive assessment of the operational and security risks relating to the payment services has to be carried out by the payment service providers (PSP), or it can be delegated / outsourced to a third entity (e.g. external audit firm). In case this is a responsibility of the PSP, it is not clear, whether it has to be carried by the independent internal audit department, or it has to be carried out by the department responsible for the risk function in the PSP.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/04 – Guidelines on ICT and security risk management - repealing EBA/GL/2017/17
  • ID: 2018_4231
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/07/2019

COREP C06.01 template - Consistency of the EBA taxonomy control v6288_m

Is the control v6288_m consistent with the COREP ITS?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4537
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/07/2019

Development Banks in the template C 33.00 General Government Exposure

Are development banks included in the definition of general government exposures (paragraph 42 (b) of Annex V ITS no. 680/2014) and should be reported in the template C33.00 General Government Exposures?

  • 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_4276
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/07/2019

C 17 template

Is it possible to include the positive impacts of operational risk errors in template C 17.00?

  • 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: 2018_4208
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/07/2019

Adjustments due to IFRS 9 transitional arrangements included in RWAs and interaction with validation rule v3689_s in template C5.01.

In template C5.01 validation rule v3689_s states that R010 C040 cannot be negative, should R010 C040 be excluded from this 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: 2018_4189
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/07/2019

FINREP: COUNTERPARTY BREAKDOWN: HOUSEHOLDS

Can Personal Investment Companies (PIC) be seen as households in the Finrep counterparty breakdown? Personal investment company (PIC) means an undertaking or a trust whose owner or beneficial owner, respectively, is a natural person or a group of closely related natural persons, which was set up with the sole purpose of managing the wealth of the owners and which does not carry out any other commerical, industrial or professional activity.

  • 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_2368
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 12/07/2019

MREL requirement if resolution strategy is liquidation (no bail-in tool used)

Question 1:Should the minimum requirement for own funds and eligible liabilities (MREL) requirement be set for a bank if its resolution strategy is liquidation and there is no plan to use a bail-in tool?Question 2:What is the legal basis and the rationale for setting the MREL for the bank if its resolution strategy is liquidation and there is no plan to use a bail-in tool?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4253
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 28/06/2019

Calculation of institution-specific countercyclical capital buffer rates

Should the calculation of the institutions-specific countercyclical buffer rate include capital requirements arising from measures taken in accordance with Article 458 in Regulation (EU) No 575/2013 (CRR)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4220
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 21/06/2019

Scope of the corporate SCA exemption.

Does the corporate SCA exemption apply only if the payer initiates (and transmits) payments directly to their ASPSP and not for payments transmitted via a 3rd party service provider (i.e. a PISP)?

  • 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_4693
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/06/2019