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List of Q&A's

C 32.02 - Prudent Valuation: Core approach (PRUVAL 2); column 0160 (IPV Difference) and C 32.03 - Prudent Valuation: Model Risk AVA (PRUVAL 3); column 0110 (IPV Difference Output Testing)) and C 32.04 - Prudent Valuation: Concentrated Positions AVA (PRUVAL 4); column 0100 (IPV Difference)

What sign convention is expected for “IPV Difference” amounts in templates C32.02 (column 0160), C32.03 (column 0110) and C32.04 (column 0100)? Should validation rule v6341_m ({r0020} <= {r0010}, i.e. o/w Trading Book <= Total Core Approach) be modified to evaluate the absolute values in the equation?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2019_4924
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

C 32.02 - Prudent Valuation: Core approach (PRUVAL 2); column 0260 (DAY1 P&L) and C 32.03 - Prudent Valuation: Model Risk AVA (PRUVAL 3); column 150 (DAY1 P&L)

What sign convention is expected for “Day 1 P&L” amounts in templates C32.02 (column 0260) and C32.03 (column 150)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2019_4923
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

The C 05.01 template seems not compliant with CRR2

The 494b of CRR2 relates to Grandfathering of own funds instruments and eligible liabilities instruments and indicates that : " 1. By way of derogation from Articles 51 and 52, instruments issued prior to 27 June 2019 shall qualify as Additional Tier 1 instruments at the latest until 28 June 2025, where they meet the conditions set out in Articles 51 and 52, except for the conditions referred to in points (p), (q) and (r) of Article 52(1). 2. By way of derogation from Articles 62 and 63, instruments issued prior to 27 June 2019 shall qualify as Tier 2 instruments at the latest until 28 June 2025, where they meet the conditions set out in Articles 62 and 63, except for the conditions referred to in points (n), (o) and (p) of Article 63." We have to classify some instruments in Grandfathered instruments but without applying the same percentage than CRR1, but the C 05.01 template is not appropriate because it is not updated. How do we have to fill this template to be consistent with the C01.00 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: 2019_4851
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Diversification benefits of upside uncertainty in column 0120 C 32.02

Where should diversification benefits of the upside uncertainty shall be included?

  • 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: 2019_4626
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

COREP V2.8 - C32.02 - Prudent Valuation : Fall back Approach

Should the detail of fair value adjustments for the Core approach be reported in the information for the fall back approach?

  • 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: 2019_4555
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Col 040 of Corep: C 32.04 - Prudent Valuation: Concentrated Positions AVA (PRUVAL 4) report

As per article 14 (details available below), col 040 of Corep C32.04 report is quite subjective. But to the best of our interpretation can we say that its a percentage value and is computed as Col 040 = ( CONCENTRATED POSITIONS AVA (Col 080) / Total CONCENTRATED POSITIONS AVA )* 100

  • 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: 2019_4519
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Reporting of template C17.01

1) Should all loss adjustments regardless of the Date of Occurrence of the original loss event be reported?2) For the rows relating to "Loss adjustments relating to previous reporting periods" (rows x40), should the adjustments be subject to materiality thresholds? Can the threshold used for registration of losses be applied also to loss adjustments?3) How should grouped losses split across multiple business lines be reported on row 910 "Number of events (new events)"? In case the loss is reported on multiple business lines, the row 910 will be lower than the sum of loss events reported on individual business lines.

  • 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_3740
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Gross carrying amount of financial instruments measured at FV through other comprehensive income

Clarification of gross carrying amount of financial instruments measured at FV through other comprehensive income defined in Annex V in Final draft ITS amendments due to IFRS 9.

  • 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_3318
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

FINREP Taxonomy 2.7 Treatment of ECLs on FVOCI Assets

ECLs on FVOCI assets are recognised in equity, as per IFRS 9.5.5.2. How should these be treated on FINREP template 4.3.1?

  • 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_3146
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Basis of reporting value - C 04.00 row 840 - Own funds based on Fixed Overheads

Please clarify the basis for reporting this number should it be on the basis of a risk weighted exposure or an own funds requirement.exposure at 8%

  • 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_1574
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Obstacle to the provision of payment initiation and account information services

Should Article 32.3 of Regulation (EU) 2018/389, read together with paragraphs 33 to 41 of the Opinion of the European Banking Authority on obstacles under Article 32(3) of the RTS on SCA and CSC, be interpreted so as to consider that interface implementations that require, in a redirection approach, Payment Initiation Services Providers (PISPs) to always transmit the payer’s IBAN to initiate a payment order, are an obstacle to the provision of payment initiation services because the payment service user is required to manually enter their IBAN while in the PISP’s domain? Should Article 32.3 of Regulation (EU) 2018/389 be interpreted identically where the interface implementations require Account Information Service Providers (AISPs) to always transmit the IBAN(s) of the account(s) to be accessed, therefore requiring the payment service user to manually enter their IBAN(s) while in the AISP’s domain?

  • 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: 2021_5763
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Use of new technology for SCA

Is a Payment Services Provider (PSP) allowed to adopt innovative technologies for verifying Payment Services Users (PSUs) where the PSP maintains fraud levels below a certain threshold?

  • 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: 2020_5621
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Use of behavioural data for SCA

Can a Payment Service Provider (PSP) use behavioural data and auditable scores to apply Strong customer authentication (SCA) in a way that protects consumer privacy?

  • 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: 2020_5620
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Independence of the elements for SCA

Can a Payment Service Provider (PSP) apply Strong customer authentication (SCA) using elements from the same category provided that the elements are independent (i.e. breach of one does not compromise reliability of the other elements)?

  • 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: 2020_5619
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

On the requirements for 'inherence' in strong customer authentication (SCA)

Do the elements required for ‘inherence’ in strong customer authentication (SCA) provide the complete authentication or can they form a part of an authentication decision with some non-biometric elements and still satisfy the inherence condition, for example, as one element of a user profile of several elements. For example, if the biometric, say keystroke dynamics, provides 50% of the decision and other characteristics (e.g. device data, location data) provide the other 50%, does this satisfy the requirement for inherence assuming the condition for 'very low probability of unauthorised access' is also satisfied and that another SCA condition, 'knowledge' or 'possession' is also satisfied? if so, is there a threshold, say 50%, below which it ceases to qualify as 'inherence'?

  • 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: 2020_5353
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Contingency Measures under Article 33

Does fallback access to a secondary instance of the dedicated interface in a different data center with dedicated resources, provide an acceptable strategy and plan for the contingency mechanism?

  • 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_5054
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Application of the strong customer authentication (SCA) in case of refund

Does a refund, which is considered as an electronic payment transaction, be subject to  strong customer authentication (SCA)? Does a merchant that initiates a refund request be considered as a payer? If so, does a Payment service provider (PSP), that holds the payment account of a Merchant, have to set up SCA each time his Merchant is doing a refund from its payment account?

  • 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_4855
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

The use of the Collateral Simple and Comprehensive Methods under the Large Exposure regime

Does the phrase "where it is permitted to use" referred to in the third sub-paragraph of Article 403(1) of Regulation (EU) No 575/2013 (CRR) intend to prescribe that the treatment for collateralised exposures specified under Article 403(1)(b) is available for: • those institutions which are allowed to use both the Financial Collateral Simple and Comprehensive Methods?; or • collateral types which are eligible for both methods?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_793
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 20/04/2021

Legal requirements for the authentication procedure when SCA exemptions are applied for remote payment transactions

What are the legal requirements for the type of authentication procedure used when conditions for the application of of Strong customer authentication (SCA) exemption for remote payment transactions are fulfilled?

  • 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: 2020_5673
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/04/2021

How to use bank guarantees instead of PII

Is it acceptable to use third party (other than credit institutions) commitments that are covered by a guarantee from a credit institution as a comparable guarantee instead of professional indemnity insurance (PII)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/08 - Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance
  • ID: 2020_5335
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:
  • Published as final Q&A: 09/04/2021