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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

Deduction requirements in accordance with Article 36(1) (f), (h) and (i) CRR: Netting of long and short positions in intermediate entities in the context of Article 15e (7) of Delegated Regulation (EU) No 241/2014 (“RTS Own Funds”)

Can an institution, in applying Article 15e (7) of Delegated Regulation (EU) No 241/2014 for the purpose of fulfilling the deduction requirements in accordance with Article 36(1) (f), (h) and (i) CRR – provided that all the conditions of Article 42 CRR are met - net long positions in an intermediate entity (such as an ETF) with corresponding short positions? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2017_3543
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 02/03/2018

CIU Correlation Test

When applying the correlation test outlined in Article 350(2b) to a given CIU position in order to determine the appropriate capital treatment for position risk, may an institution adjust the historical prices of the CIU to reflect solely those price movements which relate to the position risk of that CIU?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3538
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Reference to Chapter III in Article 96(3)(b)

Is the reference to Chapter III in Article 96(3)(b) correct?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3703
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Enforce a third country resolution proceeding

How should the outcome under Article 94(4)(d) be achieved and in what way is that article different from the provision under Article 68?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3702
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Clarification on the authority responsible for the DGS

Which exactly is the authority responsible for the DGS referred to in Article 88?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3701
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Other groups or colleges in Articles 88(6) and 89(4)

Could you please explain what “other groups or colleges” can carry out the work assigned to the resolution colleges with regard to Articles 88(6) and 89(4)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3700
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Intervention of the resolution fund to cover for losses due to creditors / liabilities excluded from bail-in

Can Article 101(2) of Directive 2014/59/EU (BRRD) be interpreted in the way that even if all bail-inable creditors have been subjected to bail-in and losses are still not covered, a bridge bank would not be allowed to take on the remaining losses and thus resolution would not be possible?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3699
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Valuation in Article 36

How should the resolution authority perform the valuation mentioned in Article 36 of Directive 2014/59/EU (BRRD) before making the decision initiating resolution if it is not entitled to require certain information from the particular entity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3697
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Treatment of cash provided as a collateral under issued guarantees and letters of credit

Should cash provided as a collateral under issued guarantees and letters of credit be included for the calculation of the total expected cash outflows under the LCR according to CRR Articles 421(1)a, 421(5)(a) or 422(2)(a)? If included, then should this collateral be treated as retail term deposits (term is being considered as the expiry of the issued L/C)? What outflow rate should be applied for such deposits?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2016_2828
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Reference to value in Article 48(2)

Does the reference to “value” in Article 48(2) refer to the “face value” (“notional amount”) or to the “market value”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3629
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 26/01/2018

Calculation of general risk capital requirement for underwriting commitment regarding bond issuance and bond issuance programs under duration-based method specified in Article 340 of the CRR.

How should the capital requirement under duration-based calculation of general risk specified in Article 340 CRR be calculated where an institution is acting as an underwriter in bond issuance or bond issuance program? In particular, how to calculate the capital requirement before fixing of the coupon rate for bonds being issued and after that date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3450
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 19/01/2018

Write down or convert bail-inable liabilities following Article 48(3)

How would the resolution authority write down or convert bail-inable liabilities referred to in point (e) of Article 48(1) of Directive 2014/59/EU (BRRD) without previously reducing or converting the other instruments, regardless of the terms mentioned in points (a) and (b) of Article 48(3)?How should "substantially" in Article 48(5) be interpreted exactly?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3630
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 19/01/2018

Recognition of non cash variation margin in the calculation for replacement cost of derivatives for Leverage Ratio

In the leverage ratio exposure calculation of non-client cleared derivatives can non cash variation margin be deducted?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2017_3267
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 19/01/2018

The treatment of Physical Stock balances

The ITS states firms should report the name of the top ten issuers/counterparties of unencumbered assets or undrawn committed liquidity lines granted to the institution shall be recorded in column 010 in a descending fashion.-       If a firm holds gold or other commodity stocks, does column 010 (counterparty name) need to be populated?-       Should all physical stock balances be reported on one line? 

  • 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_2742
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Definition of 'carrying amount' for the purposes of templates C 67.00, C 68.00 and C 69.00

In the guidance annexes for DPM 2.7 for ALMM returns C 67.00, C 68.00 and C 69.00 (Annex XIX) the requirement for ‘volume’ and ‘amount of funding’ has been further specified to ‘carrying amount’ for these templates only. Annex XIX does not define ‘carrying amount’ for liabilities – with reference to the ALMM templates mentioned, should it include accrued interest?

  • 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_3305
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Coins and banknotes in counterbalancing capacity ALMM

How should we report 'Coins and banknotes' in counterbalancing capacity sheet (C 71.00) of ALMM report?

  • 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_3097
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

C 69.00, Prices for various lengths of funding - Spreads calculated in different currencies

The EBA Q&A 2015_2204 confirms that funding spreads must be calculated for all the funding products irrespective of the related currency of issuance.However, the methodology that needs to be applied in order to convert funding spreads calculated in foreign currencies to the reporting currency is not clear.This concept is relevant for funding having an original maturity of both longer and shorter than 1 year.

  • 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_3087
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

C 67.00, Concentration of funding by counterparties- third party mandates

Banks are receiving funds from third party institutions under asset management agreements. The agent banks therefore may include these funds under their on balance sheet liabilities. Accordingly, shall third party funds be considered for the calculation of this metric if they are included in the agent’s balance sheet? Moreover, may these funds be considered as funding and reported per single counterparty?

  • 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_3086
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

C 67.00 Concentration of funding by counterparties- Cash collateral received for derivatives

In the context of CSA collateral agreements, banks can receive collateral in the form of cash or securities in order to mitigate the counterparty credit risk coming from derivative transactions. In the case that cash collateral is received, this amount should be reported in bank’s liabilities even if the associated derivative is reported as off balance sheet. In the aforementioned case, shall cash collateral be considered as a source 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: 2017_3085
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018