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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

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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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

FINREP Template F 16.07 - Accumulated Impairment

Validation rule v3956_s requires all values presented in column 040 (Accumulated impairment) of template F 16.07 to be negative. The row labels on rows 060 and 100 state “Impairment or (-) reversal of impairment”. As a result, column 040, presented negative, appears to only allow the disclosure of accumulated net reversals of impairments. Please could we receive clarification that this validation 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: 2015_2143
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP Templates F 01.02 and F 43.00

The closing balance of pending legal issues and tax litigation provisions is presented on both row 210 of template F 01.02 and column 040 of template F 43.00. However the guidance reference differs between the two templates. Please confirm which set of guidance should be followed?

  • 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_2140
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP Template 19 - column 050 - of which: Performing forborne exposures under probation

Due to the amended wording, it is unclear, whether only performing forborne exposures under probation which have been reclassified out of the non-performing forborne exposures category shall be reported in column 050 or all performing forborne exposures under probation which have been reclassified out of non-performing category at any time in the past. Regarding the two examples given below, the question is if both exposures have to be reported in column 050 of template F 19.00 or only exposure A? Exposure A was classified as non-performing with forbearance measure and fulfilled all required exit criteria mentioned in paragraph 157. Thus, exposure A was reclassified out of the non-performing forborne exposures category and has to be reported in column 050 as long as it does not fulfil the exit criteria of paragraph 176. Exposure B was classified as non-performing 2 years ago, no forbearance measure was granted. One year ago, exposure B fulfilled all exit criteria of paragraph 156 and was reclassified as performing. Six month ago, on exposure B an forbearance measure was applied which has not led the exposure to be classified as non-performing. Does exposure B have to be reported in column 050 of template F 19.00 due to the fact it was reclassified out of the non-performing category (without forbearance measure) one year ago?

  • 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_2056
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Reporting on "collateral received" and "financial guarantees received" in columns 170 and 180 of template F 19.00

Should be included in columns 170 and 180 of template F 19.00 also collateral received on performing exposures with forbearance measures?

  • 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_1880
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Definition of "Refinancing" for the purpose of reporting in columns 040, 080 and 160 of template F 19.00

What is the appropriate definition of "Refinancing" for the purpose of reporting in columns 040, 080 and 160 of template 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: 2015_1879
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

F 12.00 - changes of counterparty sector

In FINREP template F 12.00 movements in allowances for credit losses in the current year are reported taking into account the credit loss assessment method and the relevant counterparty sector. It is possible that the counterparty sector changes within the reporting time frame (i.e. from the date of the opening balance in column 010 to the reporting date, that is the date of closing balance in column 070). If this is the case, does the reporting institution take into account the counterparty sector as at the reporting date? Or are such changes reported in column 060 Other adjustments?

  • 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_1844
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FORBORNE PERFORMING/CLASSIFICAZIONE CLIENTE - FORBORNE PERFORMING / CLIENT CLASSIFICATION

Since the concession of more favourable conditions as part of commercial practice is not comparable to a forbearance measure, if, during the probation period, the client (forborne performing), once their situation has returned to normality after largely overcoming potential ‘difficulties’, were to request an adjustment of the conditions in line with other competing banks, if the bank met the request for obvious reasons of expediency, would it then be forced to reclassify the client?Posto che la concessione di condizioni più favorevoli, rientranti nella prassi commerciale, non è equiparabile ad una misura di forberance, se nel periodo probatorio il cliente (forborne performing), tornato in condizioni di piena regolarità avendo ampiamente superato potenziali “difficoltà”, richiedesse un adeguamento delle condizioni rispetto ad altre banche concorrenti, a fronte della adesione della banca alla richiesta per evidenti ragioni di opportunità, la stessa si vedrebbe quindi costretta a ri-classificare il cliente?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1841
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Treatment of ‘short-term’ exposures - Trattamento delle esposizioni a “breve termine"

With regard to short-term exposures involving renegotiations triggered by financial difficulties of the debtor – hence forborne – we ask that the deadline after which the anomalies and subsequent modifications in use must be considered for forborne purposes (past due invoices not paid by a certain date, tied-up amounts, time given for covering outstanding claims, etc.) be established objectively beforehand.Con riferimento alle esposizioni a breve termine in presenza di rinegoziazioni dovute a difficoltà finanziarie del debitore e dunque forborne si chiede di stabilire in modo oggettivo e predeterminato la tempistica oltre la quale le anomalie e le successive modifiche di utilizzo devono essere considerate ai fini forborne (fatture scadute e non rimborsate oltre una certa data, importi immobilizzati, tempi per la copertura degli insoluti ecc.).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1839
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Forbearance of Non-performing Exposures

A clarification regarding the scope of application for forbearance of Non-performing Exposures is required.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1838
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Reporting of overdue factoring contracts

In the case of trade finance (factoring) contract with multiple accounts receivable (corresponding multiple debtors) of which only single one is past due, should the carrying amount be reported (in the table F 07.00 Financial assets subject to impairment that are past due or impaired) at the single debtor (single account receivable) level that is actually past due or general contract level? Should it be differently reported in the case of factoring contract with the recourse right and without the recourse right?

  • 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_1804
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Validation rules v1026_m to v1029_m and v1372_m to v1376_m.

According to IAS 24.19 " The disclosures shall be made separately for each of the categories" - in ex. subparagraph a "Parent and entities with joint control or significant influence" it is not mentioned that individuals in subparagraph f "Key management personnel of the entity or its parent "and/or g "Other related parties" shall be eliminated. The case is that subparagraph a to e deals with organisationunits while f and g deals with individuals, and there is not mentioned any kind of exclusion between the categories. The problem is that the validationrules assume the opposite ex. v1375_m: sum({F 31.02, r040, (c010-050)}) <= {F 02.00, r200,c010}

  • 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_1749
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Inconsistencies in FINREP validation rules F01.01 versus F04.03

According to F01.01 row 260 should be specified in table F04 (and F40). However, the validation rules v3390_i, v3394_i, v3398_i, do not permit this: v3390_i : {F 01.01, r070 , c010}=={F 04.01, r010 , c010} v3394_i : {F 01.01, r110 , c010}=={F 04.02, r010 , c010} v3398_i : {F 01.01, r150 , c010}=={F 04.03, r010 , c030} How should investments in Venture capital companies which are classified as Associated companies 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: 2014_1666
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP template 9.2

In FINREP template F 9.2 (Other Commitments Received) what is the nature of the Commitments to include in this section? Does non-mandatory commitments as per example promissory notes received or confort letters should be considered as part of this section?

  • 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_1661
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019