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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

Promise to pay and financial difficulties

If a customer misses a payment he or she can promise to pay the amount due in the same month (after we have contacted our customer). Should we define such a situation as a promise to pay or as a payment reminder? We have currently defined this situation as a promise to pay (‘Toezegging’ in Dutch), but that may diverge from the EBA perception of the associated risk with a promise to pay. As there have been several discussions on this topic with our supervisor we would appreciate EBA guidance. This should provide us with sufficient information to define this event in such a way that there can be no misinterpretations about meeting forbearance criteria.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3463
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Disclosure of the difference between the fair value of a loan portfolio acquired/originated by a Bank and its contractual value

The fair value of a loan portfolio acquired/originated by a Bank differs from its contractual value. This difference (fair value adjustment on initial recognition (the “adjustment”)) has to be recognised in accordance with IFRS 3. In such case and since there is no separate column for this component, shall we reflect this adjustment in Template 4.4 row 170 ‘Loans and advances’ - under gross carrying amount (c010-c020) or under stock of provision (c030-c050)? We note that the issue of reporting this adjustment also arises on several templates which have no separate column for this component, namely F6, F7, F12, F20.4, F20.7, F18 and F19.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3431
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reporting of assets credit-impaired at purchase within template F 04.03.1 and F 04.04.1

How shall row 190 (columns 015-070) within template 4.3.1 be filled in order to fully comply with, in our interpretation, contradictory attributes stated in the terms of both rows and columns?

  • 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_3410
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Precisions on the Entity Code on COREP Solva Group (C06.02) and FINREP F40.01

Is the EBA expecting a specific relation between the column 020 in the COREP C06.02 and the column 020 of the FINREP F40.01 template ? The annexes 2 (solvency) and 5 (FINREP) of the regulation 680/2014 do not bring any information regarding an expected accordance, and only indicate that the code should be unique for each line of the template. However, those codes seem to have the same purpose, and the same entities are likely to be reported on those templates on each remittance. Therefore : - Is an entity reported in both C06.02 and F40.01 supposed to share the same code on the columns 020 of the both templates? - Is an entity reported in one of those templates supposed to share the same code in the next remittance of the template? Similar questions can be asked regarding the columns 010 of the large exposures templates (C27 to C31).

  • 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_3390
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Reserves of Equity Accounted Entities

How should dividends received by the reporting entity from an equity accounted entity be classified in the equity rows of Template 1.3 and Template 17.3 ?

  • 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: 2017_3374
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

“Past due” columns: How to count number of days for “1 year” and “5 years” past due?

In Template F 18.00 the “cross carrying amount / nominal amount” and the “accumulated impairment, accumulated negative changes in fair value due to credit risk and provisions of non-performing exposures” have to be allocated to different “past-due” columns according to its number of days past due. How many days past due have to be assumed in order to allocate an exposure to past-due column “1 year” or “5 years” respectively?

  • 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_3301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Template F 31.00 Related parties column 010 and column 020.

How should be performed the split between column 010– “Parent and entities with joint control or significant influence”- and column 20 “Subsidiaries and other entities of the same group”? In column 010 – “Parent and entities with joint control or significant influence”, should be reported only the balances with our Head Office or also should be included the upper hierarchy level of our shareholder and their related group entities? In column 020 – “Subsidiaries and other entities of the same group”, should be reported only our affiliates or also should be included the upper hierarchy level of our shareholders and their related group entities?

  • 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_3032
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Transferred financial assets Template 15

Should in F15 template that collateral obtained from reverse repurchase agreement (assets) be reported that is given as collateral in a repurchase agreement (liability)?

  • 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_2926
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

FINREP -contents of template F40.01 Group Structure

During the last reporting of 31/12/2015 we received a return from ACPR about the way of filling this template (Fin. 40.1), we are coming back to you because we need additional information to correct if necessary our last statement 31/12/2015.

  • 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_2820
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Counterparty breakdown by sector – definition of other financial corporations and non financial corporations

Article 35 in Annex V of Finrep defines 'other financial corporations' as all financial corporations and quasi-corporations other than credit institutions such as investment firms, investment funds, insurance companies, pension funds, collective investment undertakings, and clearing houses as well as remaining financial intermediaries and financial auxiliaries; ‘Non-financial corporations’ are corporations and quasi-corporations not engaged in financial intermediation but principally in the production of market goods and non-financial services according to the ECB BSI Regulation. Subsidiaries set up within non – financial group to issue debt instruments or to perform liquidity management activities within the group should be considered as ‘other financial corporations’ or ‘Non-financial corporations’?

  • 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_2793
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Counterparty Zuordnung Abwicklungsanstalten

Für FinRep sind in verschiedenen Tabellen Aufgliederungen nach sog. Counterparties erforderlich. In der Praxis stellt sich häufig die Frage, in welchen Sektor Abwicklungsanstalten einzuordnen sind. Hierunter fallen in der Praxis regelmäßig gehaltene Positionen ggü. der Heta Asset Resolution AG, der Erste Abwicklungsanstalt (EAA) sowie der FMW-Wertmanagement. Auf Basis der Counterparty-Definition in Annex V (1.35) ist in der Praxis ein eindeutige Zuordnung nur schwer möglich. Insofern stellt sich die Frage nach einer aus Sicht der Aufsicht korrekten Zuordnung von gehaltenen Positionen gegenüber den o.g. Gesellschaften.For Financial Reporting, breakdowns by ‘counterparties’ are required in various tables. In practice, this frequently gives rise to the question of which sector should be used for deconsolidated environments. This includes, in practice, positions regularly held in respect of Heta Asset Resolution AG, Erste Abwicklungsanstalt (EAA) and FMS Wertmanagement. On the basis of the counterparty definition in Annex V (1.35), a clear classification is difficult in practice. In this respect, there is a need to correctly (from a supervisory perspective) classify positions held in respect of the above-mentioned companies.

  • 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_2789
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Definition of mortgage loan and its collateral in FINREP template 13 (F13.01)

1. What kind of loans should be reported as “Mortgage Loans” for the purposes of FINREP template F13.01? 2. What kind of commercial and residential property should be reported as collateral for “Mortgage Loans” for the purposes of template F13.01?

  • 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_2754
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

FINREP Group Structure Template 40.02

For entities which are consolidated as part of the Group, but where we do not have any legal ownership over these entities, what should be included as the Holding Company on FINREP template 40.02?

  • 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_2670
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Trades receivables towards Central Banks

Could you clarify why in the FIN 5 template, it is not possible to put an amount in the cell « Trades receivables towards Central Banks” (Row 30 Column 10)?

  • 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_2546
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Allocating transfer from Share Premiun to Other components of equity.

As per the cell { r160, c020} is greyed in F 46.00 template, transfers from share premiun to other items of equity and other increases or decreases are not possible to be reported. On the other hand, the cell {r100, c020} should be used to reclassify "Share Premiun" to "Other reserves" but, this line is not a correct source of equity change, since it is not a reduction of capital but a share premiun. Where or how transfers from share premiun to other reservers must 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: 2015_2492
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Forbearance – past term interest only mortgages

Should interest only mortgage exposures where the customer has not repaid the capital at term but continues to pay interest and is not considered to be in financial difficulty, ever be considered as forborne?

  • 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_2474
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

FINREP – Forborne Exposures

Is the definition of concession referred in paragraph 164 to be read as including all non-payment related concessions?

  • 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_2450
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Exit criteria from non-performing forborne category

According to paragraph 157 of Annex V, a condition to exit the non-performing forborne category is that a period of (at least) one year has passed since the forbearance measures were applied (“cure period”). During this period, there must not be any past-due amount or concern regarding the full repayment of the exposure according to the post-forbearance conditions. If an amount due is unpaid during the “cure period”, the latter shall be considered as “discontinued” or “suspended”? In the former case, the counting of the year should restart from the date of any repayment; while in the latter case, the counting of the year shall continue since the date of any repayment.

  • 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_2429
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Exit Criteria NPE

With regards to the EBA Implementing Technical Standard and specifically to the NPE exit criteria we would like to ask for your advice on how to handle the following case:Customer A is a performing exposure. Account 3 presents 91 dpd and as a result the whole customer is classified as NPE. Account 1 and 2 are classified as such due to contagion.Customer A - Performing exposureAccount Balance % on total Days past due NPEAccount 1 50 5% 0 50Account 2 100 10% 0 100Account 3 850 85% 91 8501.000 100% 1.000On the other hand Customer A is now a non performing exposure. It presents arrears over 90 dpd in an immaterial account i.e. account which is < 20% of the total customer balances.Customer A - Non performing exposureAccount Balance % on total Days past due Performing - 1st option Performing - 2nd optionAccount 1 50 5% 91 0 0Account 2 100 10% 0 0 100Account 3 850 85% 0 0 8501.000 100% 0 950The question is should we upgrade Accounts 2 and 3 into performing, leaving Account 1 as an NPE or the whole exposure retated to the customer must remain as NPE? Please always assume that the customer is not impaired and no concerns regarding the full repayment of the debt exists. Based on paragraph 156 of the EBA ITS, the first option is valid, however this is not in line with the NPE entry criteria. In our opinion the second option is the correct one. 

  • 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_2378
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019