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List of Q&A's

Securitisations reporting in C 09.04 for v 2.8

How should the securitisations under the new framework be reported in template C 09.04 in v 2.8?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2018_4408
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Reverse repos (Reverse Repurchase Agreements) in AE-Assets Encumbrance

RE 680/2014, Annex XVI, § 2.1.1.14 (b) deals with Repos / Matching (or Reverse) Repos in the AE-Assets Encumbrance reporting. Questions : 1)where must be reported in AE-ASS (F32.01) and by impact in AE-ADV1 (F36.01) the cash received by the reporting institution from its Reverse Repos ? because it should be registered among the Encumbered Assets whereas the (iv), taken over below in Background section doesn’t evoke the treatment for the carrying amount, contrary of Repos in the paragraph (iii). 2) the paragraph (iv) of the mentioned article indicates that the fair value of the collateral of reverse repurchase is reported including AE-SOU (F32.04), r050, c030 and 040 : is c030 provided for Reverse Repos and c040 for Reverse Repos regiven in Repos ?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4372
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Validation rule v0853_m - Framework release 2.8

In tables F10.00 and F11.01 should the notional amount of derivatives be reported if the fair value is equal to zero?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4355
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

FINREP Locom valued debt instruments: Reporting of "Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Could it be that the following validation rules 5319_m until v5331_m are not correct for LOCOM valuated debt instruments. Should  "Accumulated negative value adjustments on LOCOM assets - credit risk induced"  be reported under accumalated impairment and not under "Accumulated negative changes in fair value due to credit risk on non-performing exposures"?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4336
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Finrep Solo GAAP: The following validation rules v5476_m until v5489_m are missing the column"Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Dear Could it be that the the column "Accumulated negative value adjustments on LOCOM assets - credit risk induced" is missing in the validation rules from v5476_m until v5489_m?

  • 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_4335
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Difference in reporting requirements for C71 as per the EBA Annotated Reports and ITS Monitoring Metrics

There is some confusion in relation to two documents provided by the EBA on the ITS Supervisory Reporting website. In regards to the C 71.00 report, on the Annoted Report (see screenshot attached) it is shown clearly that the counterparty should not include "Central Banks" - but tat the same time in the ITS document also provided by the EBA (unable to attach more than one attachment for reference) for C 7.001, they mention clearly that "Central Banks" should be included in the Issuer/Counterparty Sector.

  • 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_4217
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Accumulated other comprehensive income in template C.01.00

Is the accumulated other comprehensive income in template C.01.00 the same amount than in row 090 in F.01.03? Is row 280 in F.01.03 also taken into account?

  • 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_4116
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Report gross or netted cash flows in the row 360 of C66 (maturity ladder) of non-forex and non-option-like derivatives under a valid netting agreement but without collateral agreement

« In the Annex XXIII (Maturity Ladder Instructions), for the row 360 ("1.5 Derivatives amount payables other than those reported in 1.4") , paragraph 2(b), it is stated that "flows related to other contracts than those referred to in point (a) shall be included by projecting the gross contractual flows of cash in the respective time buckets in lines 1.5 ‘derivatives cash- outflows’ and 2.4 ‘derivatives cash-inflows...’". Suppose that there is a group of derivatives (non-forex, non-option-like transactions) traded with the same counterparty under a valid bilateral netting agreement but without a collateral agreement in place, should netted cash flows per counterparty or gross cash flows be reported in row 360? If the netted cash flows should be reported in row 360, should the netted amount be calculated per day, or per time bucket defined for C66 report? For example, in C66, there is a time bucket 'Greater than 7 days up to 2 weeks', can we net an inflow of day 8 with an outflow of day 9 and then report only the net amount in row 360 (if negative) or row 670 (if positive)?”

  • 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_3943
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Low Credit Risk Template 4.4.1 and 4.3.1

Regarding the Column "of which: Instruments with low credit risk" detailed in the Template 4 series. Is there an expectation to have this populated by institutions which have not elected to adopted the practical expediency which IFRS 9 allows for the implementation of the new standard?

  • 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_3594
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Reporting of fees and levies in FINREP template F 02

How each the following expenses should be classified in FINREP template F 02, that is, should they be reported in row 350 (Other operating expenses), row 380 (Other administrative expenses), or under a different item? - contribution to the deposit guarantee scheme pursuant to national legislation implementing Article 10(3) of Directive 2014/49/EU of the European Parliament and of the Council - contribution to the Single Resolution Fund pursuant to Article 70(3) of Regulation (EU) No 806/2014 of the European Parliament and of the Council and Council Implementing Regulation (EU) 2015/81; or to a national resolution fund - a bank levy or a supervisory fee, such as the SSM Supervisory Fee (Regulation (EU) No 1163/2014 of the European Central Bank) or the “Dutch bank tax”.

  • 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_3574
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Certfication in relation to a Technical Service Provider (TSP)

When performing the role of a Technical Service Provider (TSP) is the TSP required to update the certificate received from the Third Party Payment Service Providers (TPP) (to demonstrate our involvement) to enable the Account Servicing Payment Service Provider (ASPSP) to authorise the certificate and provide the appropriate requested data back through to the TPP and establish the session? Is this same certificate required for every type of transaction request and must it be real time checked by the ASPSP and how does this impact our role as a TSP?Also, by introducing a TSP between a TPP and an ASPSP is the concept of private keys and the transport layer broken, due to the introduction of a TSP between the TPP and the ASPSP? Finally, are there limits to the number of roles involved in the chain in terms of the certification or do we just need to be able to demonstrate the link back to the point of origin for the certificate (the TPP)?

  • 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: 2018_4375
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/05/2019

Authentication code

Is it allowed to use the (authenticated) session that a user has (after logging in (with or without SCA)) as 1 of the authentication factor when performing SCA for a payment transaction?For example: A customer logs in with its username & password (knowledge) + SMS One Time Password (possession). Once in his online banking environment he looks at his statements. Within that same session (that ends after 5 minutes inactivity) he makes a payment.The question is if for authenticating the payment it is required to perform SCA again or if the authenticated session (based on the previous authentication) and a second SMS One Time Password (possession) that dynamically links the payment would suffice.

  • 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: 2018_4141
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/05/2019

Information to be provided / made available by ASPSP to payment initiation service provider (PISP)

In the context of PIS:(a) shall the ASPSP, upon initiation of the payment session, provide or make available to the PISP the IBANs/account numbers for all payment accounts from which the user can transfer funds, and the associated currencies; and(b) shall the ASPSP, in each communication session, provide or make available to the PISP/AISP the name of the payment service user that is accessing the accounts.

  • 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: 2018_4188
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 10/05/2019

Breakdown of exposures by residual maturity

In the template C 33.00 breakdown of total exposures by residual maturity is required (rows 170 - 230). However from instructions it is not clear into which time bucket following exposures should be classified: - exposures at default - exposures without residual maturity - past due exposures.

  • 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_4164
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/05/2019

Validation rule v0682_m - DPM 2.7.0.1

Is the validation rule v0682_m correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3992
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/05/2019

Definition of a qualifying holding

In order to identify a qualifying holding in an undertaking, for the purposes of the definition laid down in Article 4(1)(36) CRR, has the possibility to exercise a significant influence over the management of an undertaking to be accompanied, as a necessary precondition, by an even minimum level of holding in that undertaking (as suggested by the English or Italian language version of CRR)? Or, conversely, can the definition of qualifying holding in Article 4(1)(36) CRR be met, in cases where the possibility for a person to exercise a significant influence in an undertaking is established, even in the absence of a minimum level of holding in the undertaking by that person?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3762
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 03/05/2019

Application of the Low Value Transaction Limits

Should the limits according the Article 16 RTS be applied to the account itself (account holder and authorized persons together) or should they be applied to the account holder (owner) and each authorized person (i.e. proxy of account holder) separately? Subsequently should the limits be applied to all remote payment transactions together or should e.g. card transactions and credit transfers be counted separately. Also should the limit be applied to all cards belonging to one person together or should the limit be applied to each card separately?

  • 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: 2018_4429
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/04/2019

Wide usage portability between Member States

Could three months’ data, showing wide usage of the dedicated interface, produced in one Member State by a regulated entity (ASPSP) belonging to an ASPSP Group, be used as evidence to support the ‘widely used’ condition in a further Member State for a separate regulated entity (ASPSP) belonging to the same ASPSP Group, on the condition that both entities employ the same dedicated interface?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/07 - Guidelines on the exemption from the contingency mechanism under Regulation (EU) 2018/389
  • ID: 2019_4638
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 26/04/2019

Applicability of Article 34 (eIDAS certificates) prior to application date of Regulation (EU) 2018/389

Is the use of eIDAS certificates mandatory for accessing payment accounts via dedicated interfaces (APIs) already prior to the application date of the Commission Delegated Regulation (EU) 2018/389, i.e. 14 September 2019?

  • 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_4630
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/04/2019

Content of eIDAS certificates if agents or outsource providers are involved

Who shall be the Subject Distinguished Name (DN) in the situation described in EBA Opinion on eIDAS (EBA-Op-2018-7) item 21? Does information on agents or outsource providers has to show up in the certificates? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4507
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/04/2019