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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

F18 & F19 Commercial Real Estate

Should we assume that the row "Commercial real estate" contains the same information as "Commercial immovable property", within F20.04? That is to say, does "Commercial real estate" request loans collateralized by commercial immovable property? Thank you very much.

  • 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_1006
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/05/2015

Currency in which the information that the institutions report to the competent authorities of the home member State must be submitted, according to art. 415, par.2. (Templates: C.51.00.w, C.51.00.x, C.52.00.w, C.52.00.x, C.52.00.y, C.52.00.z, C.53.00.w, C.53.00.x, C.53.00.y, C.54.00.a, C54.00.w)

In order to ensure uniform reporting among all entities of LCR and NSFR templates, the following question has arisen: which is the currency in which the information dealing with the significant currencies must be reported according to article 415.2?

  • 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_1042
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 29/05/2015

FINREP – reporting of negative interest

How to report the remuneration of assets with a negative interest 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2015_1940
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 22/05/2015

Treatment of specific liabilities - even deduction

What does Article 5(2) of the Commission Delegated Regulation (EU) 2015/63 mean by the requirement to “evenly deduct” certain liabilities? Could you please provide any examples?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_1893
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 22/05/2015

10 largest exposures to institutions and unregulated financial sector entities

How to count 10 largest exposures to institutions? If a reporting institution has 7 large exposures to institutions, does it have to include into report its next 3 largest (but "non large") exposures (10 alltogether) or 10 largest (but "non large") exposures (17 alltogether)? the same applies to reporting of exposures to unregulated financial sector entities.

  • 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_1351
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Report information on the 20 largest exposures to clients or groups of connected clients

An institution has to report information on its large exposure, on its 10 largest exposures to institutions as well as on the 10 largest exposures to unregulated financial entities according to Article 394 . Furthermore, an IRBA institution also has to report its 20 largest exposures sorted by the non exempted exposure value (resulting from subtracting the amount in column 320 ‘Amounts exempted’ of template LE2 from the amount in column 210 ‘Total’ of that same template, according to annex IX). In case the institution has already reported some of these 20 counterparts as large exposure or in one of the two TOP 10, does this institution: -have not report those who are already reported in the same template ? -have to complete the template with the next ones in order to report a total of 20 largest exposures ?

  • 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_1256
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Forborne exposures, Template 19, column 110

Column 110 of Template 19 provides references to Annex V.Part 2.157 and Annex V.Part 2.172(a). Our understanding is that this column requires disclosure of exposures with forbearance measures, that would otherwise be classified as performing but have not met all of the additional exit criteria extended to non-performing exposures with forbearance measures as defined in Annex V.Part 2.157 (e.g., the exposure is no longer classified as defaulted or impaired and there are no past due amounts, but only 8 months have passed since forbearance measures were extended and therefore it should remain to be classified as non-performing). We believe that the intent is to show those exposures that are performing better after the forbearance measures were extended and would be classified as performing if there were no additional exit criteria set out by Annex V.Part 2.157. Can you please confirm if this is a valid interpretation or different information is required to be reported in this column?

  • 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_1031
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Statement of Profit or Loss

1. What has to be included in 350 Other Operating Expenses and what in 380 Other Adminstrative Expenses? It is not clear what the difference between these two data points is, and to what extent we have the option to classify costs in one data point or the other. 2. Is it true that as long as in our judgement we consider a cost an operating cost, it should be included in 350 Other Operating Costs? 3. Are lessee costs, ie operating lease rentals, the only item we should be including or are required to include in data point 380 Other Administrative Expenses?

  • 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_1002
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Defintion of “micro, small and medium sized enterprises”

How should be defined the concept of “micro, small and medium sized enterprises” given by the Article 108(a)(i)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1827
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Inclusion of interim profits in CET1

If a credit institution includes interim profits in Common Equity Tier 1 capital (with the prior permission from the competent authority in accordance with Article 26(2) of the CRR), can the institution decide that in the following interim period it will not apply for a permission concerning interim profits for that (current) interim period, but to use the (previously permitted) amount of interim profits for the previous interim period? For example, a credit institution received a prior permission from the competent authority and included interim profits reported on 30 June in its CET1 capital. When calculating CET1 capital on 30 September, can it choose not to apply for a prior permission from the competent authority to use interim profits reported on 30 September and, instead, include the amount of interim profits reported on 30 June (the same amount it has included in the calculation in the previous quarter)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1242
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Client money

To what extent the deposits linked to securities accounts can be qualified of “client money”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1826
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 08/05/2015

Treatment of Sovereign Wealth Funds as non-financial customers or financial customers

If an institution has unsecured deposits from a Sovereign Wealth Fund, are those deposits from financial customers or deposits from non-financial customers?

  • 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: 2015_1764
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/04/2015

Deposits received as collateral

Under 423(6) of Regulation (EU) No 575/2013 (CRR) should the deposits received as collateral be calculated as net posted collateral in order to treat posted and held cash collateral symmetrically? What if more cash collateral is posted than held? Thus should all other posted level 1 collateral not be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1089
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/04/2015

Exposure to third country institutions and investment firms

What is the treatment for credit risk purposes of an exposure to an investment firm which is established in that third country and which is subject to the supervisory and regulatory requirements applicable to credit institutions in that country?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1968
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/04/2015

Disclosure on the basis of consolidated situation of EU parent financial holding company

According to Article 13(2) of Regulation (EU) No 575/2013 (CRR), institutions controlled by an EU parent financial holding company shall comply with the obligations laid down in Part Eight on the basis of the consolidated situation of that financial holding company. In the case where a parent financial holding company has control over two separate institutions in different member states (without any equity holdings between these two institutions), are both of these institutions obliged to disclose information laid down in Part Eight on the basis of consolidated situation of the parent financial holding company? If yes, is there possibility that one of aforementioned institutions can “outsource” disclosure obligations on the basis of consolidated situation of the parent financial holding company to the other?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1502
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 24/04/2015

Removal of Senior Management

We would like clarification on Article 28 of Directive 2014/59/EU (BRRD) envisaging the possibility to remove the senior management and also with regard to individuals. This seems the same power that is already envisaged in Article 27(1)(d) providing for the removal of managers that are unfit to perform their duties albeit linked to a different trigger; therefore different triggers could end up with the same early intervention measures.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1862
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 17/04/2015

Solvency in the context of Article 32(4)(d)

What is a solvent institution in the context of Article 32(4)(d) of Directive 2014/59/EU(BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1777
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 17/04/2015

Definition of the exposure portfolio for which permanent partial use of standardised approach can be applied for by a credit institution using the IRB approach

Can an IRB credit institution have the standardised approach applied to type of clients to whom the IRB approach is being used? I.e. if the standardised approach is approved for a specific portfolio of exposures, can this portfolio be defined by the type of client only or may it also be defined by the type of business?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1678
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/04/2015

Disclosure requirement on individual basis

What is the connection between the provisions of Article 13 and Article 433 of Regulation (EU) No 575/2013 (CRR)? When shall the institutions disclose all the information required by Part Eight and on what condition could the limited disclosure requirement be applied on individual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1379
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 27/03/2015