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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

Reporting of of the group of connected clients in C27 Identification of the counterparty (LE1) when the national reporting system DOES NOT provide a unique code for the group of connected clients

It is unclear if the group of connected clients should be reported in C27 Identification of the counterparty (LE1) when the national reporting system DOES NOT provide a unique code for the group of connected clients.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2888
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Account Data required by a ASPSP to execute a payment order via a PISP

In the context of Payment Initiation Service (PIS) where a Payment Service User (PSU) payment order is to be carried out, the Payment Initiation Service Provider (PISP) accesses the PSU e-banking account to require a payment. The PSU may: a) hold a single payment account to be debited or b) hold multiple payment accounts where only one of them is to be debited to finalize the payment order (in this case PSU has to select a payment account).With reference to both use cases and in the presence of an Account Servicing Payment Service Provider (ASPSP)’s dedicated interface, may the PSU be obliged to digit the IBAN of the account to be debited each time she/he initiates a transaction? Is the PISP always required to report the account number to be debited in the payment request or may this parameter be managed bilaterally among ASPSP and PSU (e.g.: default payment account, drop-down selection menu during the strong customer authentication (SCA) procedure, communication over Out-of-Band (OOB) channels, etc.)?

  • 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_4854
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Compliance of (1) card data (2) SMS OTP and (3) EMV 3DS behaviour-based inherence as an authentication information with the requirements of PSD2 and RTS on SCA

Could the use of (1) card data (2) SMS One Time Password (OTP) and (3) Europay, MasterCard, Visa (EMV) 3-D secure (3DS) behaviour-based inherence information as an authentication solution be considered compliant with the PSD2 and RTS on strong customer authentication and secure communication 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_4671
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Liquidity templates and instructions

We found some inconsistencies between the templates, the instructions and the CRR. Please confirm the following: 1. In template C61.00, rows 140-180 (which is 1.2.3.1 to 1.2.3.3.1) should refer to Article 427 CRR instead of Article 414. The rest of those references on sub-article basis seem correct. 2. In Annex XIII, Part I the title for row 540 is different compared to the one in the template and does not correspond the text of Annex III, point 5 of the CRR. The text of Annex XIII should be amended accordingly. The same problem is present in Annex XIII, Part II, row 610 and Annex XIII, Part III, row 590. 3. In Annex XIII, Part I the title for rows 710-730 is different compared to the one in the template. We think that this is the correct title ("... not already reported in 1.10 to 1.11.3") and suggest to change the template accordingly. 4. In Annex XIII, Part I the title for rows 740-760 is different compared to the one in the template. We think this title should be amended because the the title used in the template seems to be the correct one. 5. In Annex XIII, Part I the title for row 820 is different compared to the on in the template. We think this is the correct title ("... reported in 4.6 - 4.10") and suggest to change the template accordingly. Similar issue is present in Annex XIII, Part II, row 890 where the correct title should be the one used in the template. Also such issue is found in Annex XIII, Part III, row 870 where the correct title is the one used in the instructions and the template should be amended accordingly. 6. In Annex XIII, Part II, the title for rows 1110-1120 and the indivudual titles for rows 1110 and 1120 are identical. We suggest to take the correct titles from the template. 7. In Annex XIII, Part III, the title for row 030 is different compared to the one in the template. We think this is the correct title and suggest to change the template accordingly. 8. In Annex XIII, Part V.1, the explanation for rows 140-200 is non conistent with the template. As the instructions seem correct, we suggest yoy amend the template legal reference accordingly.

  • 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_1227
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

TPP access only with PSU involvement

Can a Payment Service User (PSU) allow a Third party provider (TPP) the access to his account only if he is involved?

  • 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_4631
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Embedded forbearance clauses

Does it lead to a forborne status of the contract if executing embedded forbearance clauses (e.g. payment holiday and partial write off), incorporated in Dutch Nationale Hypotheek Garantie mortgages?

  • 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_1411
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Refinancing

Does a derecognition on an institution’s balance sheet of a forborne contract lead to an end of the forborne exposure and end to reporting duty?

  • 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_1412
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Interest Rate Cashflows due within 30 days

Are interest rate cashflows shown in the same position in the In-/Outflow-Template as the corresponding redemption cashflows? Are the weighting factors for interest rate cash flows the same as for redemption cashflows.

  • 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_1340
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Non-Renewable loans and receivables

NSFR: Should non-renewable loans and receivables be presented as gross (not affected by general and specific allowances) or as net (affected by general and specific allowances)?

  • 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_1489
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Application of requirements on a consolidated basis to a stand-alone bank in a Member State owned by a financial holding institution in another Member State and by a third-country bank: submission of FINREP on a consolidated basis.

A stand-alone bank in a Member State that, according to Article 11 of CRR, has to respect prudential requirements on the basis of a consolidated perimeter including financial companies located in other States shall submit FINREP information on a consolidated basis, in addition to COREP information?

  • 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_1504
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting liquidity outflow of non-retail deposits

Non-retail deposits: Should the current amount outstanding or just the current amount outstanding that comes due be reported in outflows? Should the treatment be different for deposits that have to be maintained according to Art 422 (3)(4) (→ take just outstanding amounts that come due) versus non-retail deposits that do not meet criteria set out it Art 422 (3)(4) (→ take full current outstanding amount)?

  • 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_1531
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

HANDLING OF CASH COLLATERAL DEPOSIT HELD WITH OUR BANK

Bank A is solo reporter and is a small subsidiary bank owned by foreign Government of (Third) country X (51%) and Bank A (49%). In the General ledger it has a loan to a Public Sector Enterprise incorporated in the (Third) country X. This loan is backed by cash collateral provided to Bank A by the Central Bank of the (Third) Country X which covers the outstanding balance (principal) on the loan fully - only the interest remains uncovered.How shall this loan and the linked deposit be reported for liquidity purposes in the LCR templates (C 52.00 / C 53.00)?Operationally, the deposit is expected not to generate any additional liquidity buffer requirement as the deposit is expected to be returned only when the loan is fully paid, thus covering the expected outflows by the inflows.

  • 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_1624
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting of "Value according to Article 418 of CRR" of liquid assets

How should the "Value according to Article 418 of CRR" be calculated for assets which do/do not fulfill the requirements of Article 416 and/or Article 417 CRR (C 51.00 Reporting IDs 2 - 4, C 52.00 Reporting IDs 1.2.2.11 - 1.2.2.13, C 53.00 Reporting IDs 1.6.11 - 1.6.13 - without IDs 1.6.13.13 - 1.6.13.13.3)

  • 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: 2015_1752
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Validation of LCR Submission

Is validation rule v1512_m correct?v1512 m - C52.00, Row 1140 - 1210, Additional Outflows: As it is not explicitly clear from the rules or guidance as to how to treat cash assets (e.g. cash held at a bank) in this particular section, it has been interpreted that the columns to be populated are as follows: - {c030} Market Value: Represents the market value of non-cash assets (i.e. excludes cash balances) - {c040} Value according to Article 418: Represents (i) the market value of non-cash assets after the deduction of an appropriate haircut as per Article 418, plus (ii) the full value of cash balances, in line with Article 416(1)(a). - {c020} Outflow: Outflow calculated based on cash and non-cash assets as prescribed by Article 423. Based on the interpretation above, as cash balances are excluded from {c030} Market Value, validation v1512_m fails.

  • 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_1473
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Definition of "location"

Does the definition of "locations" pertains to the location of the reporting institution itself or to location of its customers, eg. debtors?

  • 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_1528
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting of retail deposits that qualify for the treatment set out in Article 421 (5a) CRR

Is it possible to report retail deposits defined in Article 421 (5a) CRR in the same way as deposits under Article 421 (1a,2) CRR for the Net Stable Funding Ratio purposes?

  • 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_1894
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Definition of undrawn committed credit facilities to report

Can you please clarify, why only those undrawn committed credit facilities shall be reported in template C60 (row 1320), which have a maturity <= 3months? 

  • 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_1994
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting the central administrative services for collective investment under the item 100 of the template F 22.02 - Assets involved in the services provided

Taking into consideration that these services may not always be related to a certain asset (e.g. services of compiling the accounting documents, services of preparing the financial reports), what value should be reported under the item 100 of the template F 22.02?

  • 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: 2014_1533
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Further clarification required on the inclusion of transactions between trade and settlement date

We would welcome further clarification on the reporting of transactions between trade and settlement dates (unsettled trades). Q&A 2013_378 implies that unsettled trades should be treated on a gross basis. However, it does make reference to underlying HQLA or non HQLA, Annex XXV (Part 2, Outflows and Part 3, Inflows) of the EBA-ITS-2015-04 on reporting for the LCR, provide specific remarks regarding forward starting transactions. In particular, the ITS provides guidance for inflows/outflows stemming from forward starting repos, reverse repos and collateral swaps, whereby, the inflow/outflow to be received/delivered shall be reported net of the market value of the asset to be delivered/received after the application of the related LCR haircut. This guidance is included in Commission Implementing Regulation (EU 2016/322 of 10 February 2016. However, there is no guidance on the treatment of unsettled outright purchases/sales of liquid assets.

  • 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_2817
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting the customer resources distributed but not managed under the item 130 of the template F 22.02 - Assets involved in the services provided

a) What value should be reported under the item 130 of the template F 22.02: the value of the resources distributed in the reporting period or the balance of such resources at the reporting reference date? b) Should the reported value be the gross amount invested by the clients (including the credit institution distribution fee) or the net amount (less the distribution fee)? c) Should the information related to money transfer services be also reported under the item 130 of the template F 22.02?

  • 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: 2014_1535
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021