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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.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

Quantification of foreseeable dividends when the dividend policy is set as a fix amount

Which amount should be deducted from interim/year-end profits pursuant to Article 26(2) CRR if a bank has a dividend policy stating that a certain specified amount (i.e. x.xx €) should be paid per share?

  • 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: 2019_4731
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/05/2020

Signature on a paper slip from a payment terminal, as a factor in a two-factor SCA

Could Signature on a paper slip from a payment terminal, be considered a valid factor in a two-factor strong customer authentication (SCA) under the RTS – and what type of element is it?

  • 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_4237
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/05/2020

HQLA treatment of euro-denominated assets held in 3rd Countries

In the LCR DA, and subject to compliance with the caps in Article 17, can all Euro denominated net liquidity outflows of a credit institution, irrespective of where they arise, be covered by euro denominated Level 1 HQLA envisaged in Article 10(1)(d) and by Level 2b HQLA envisaged in Article 12(1)(c)(ii), in the latter case if not denominated in euro nor in the currency of the credit institution’s home Member State?

  • 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: 2018_4285
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/05/2020

HQLA and amortised cost classification

If a bank holds HQLAs in the amortised cost portfolio and is able to monetise these assets can the securities, e.g. government bonds, in the amortised cost portfolio also be treated as HQLA in LCR calculation?

  • 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: 2018_3955
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/05/2020

2% threshold in template C.09.04

Which is the correct way to calculate the 2% threshold for general credit exposures in the context of the institution specific counter-cyclical capital buffer (CCB)?

  • 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_4474
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Provision of data to cover the cost of living

Does the data referred to in Article 8(4) DGSD have to be provided by the credit institution after the date on which the credit institution has become unable to repay deposits? Or is it possible for a DGS to use data which has been provided by the credit institution before the credit institution has become unable to repay? If DGS are expected to use data which is provided after the aforementioned date, does the data have to be provided specifically for calculating the appropriate amount or can/must data be used which is (mainly) provided for making the repayments?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2907
  • Topic: Rights of depositors (Eligibility, coverage level, repayable amount, repayment, claim against DGS, depositor information)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

NSFR calculation - deposits

In the context of the reporting of stable funding (i.e., C 60.00 and C 61.00), we have the following two questions: (1) How should institutions report retail term deposits with a residual maturity of four months but where early withdrawal (i.e., < three months) is possible contingent upon the payment of a penalty that corresponds to the interests due for the time that elapsed between the date of deposit and the date of withdrawal? Are these deposits to be reported in the maturity bucket “within three months” or “between three and 6 months”? (2) Considering the deposits provided under (1), what would be the treatment if these deposits are provided by wholesale customers?

  • 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_4804
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Validation rules v2.8.1

This question refers to the validation rule v5532_m. The prerequisites indicate that template F 04.02.2 triggers this validation rule. Specifically, the prerequisites are : F 06.01 and (F 04.02.1 or F 04.02.2 or F 04.03.1 or F 04.04.1). In the French Gaap environment, only F 04.02.2 is defined as compulsory but not the other templates F 04.XX. For this reason the rule may not be valid in general because all the other files are not produced. For reminder the formula is {F 06.01, r190, c010} = {F 04.02.1, r160, c010} - {F 04.02.1, r160, c020} + {F 04.02.2, r170, c010} - {F 04.02.2, r170, c020} + sum({F 04.03.1, r160, (c015, c030, c040)}) + sum({F 04.04.1, r120, (c015, c030, c040)}) Could it be possible to modify the appliance conditions of this Validation Rule ? Will it be corrected in a further evolution of the EBA VR ? Thanks

  • 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_4803
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Validation rule v6405_m

Validation rule v6405_m does not calculate right when the credit institution has only T1 capital and no T2 capital. Report is COREP own funds.

  • 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_4778
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Funding plan validation error v6223_m

Can a credit institution submit a funding plan with having an actual reverse repurchase agreement starting position and no projected positions in view of validation error v6223_m (template P01.03)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2019_4727
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 08/05/2020

ABCP programme

Does an ABCP programme meet the definition under Article 242(11) of Regulation (EU) No 575/2013 (CRR) as amended by Regulation (EU) 2017/2401 in any case, whether or not the credit risk of the financial assets acquired by the conduit is tranched into different risk categories at the programme level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4323
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 08/05/2020

EBA_v6217-6222 and EBA_v6224-622; EBA_v6230 validation rules (warnings) implementation

Does EBA_v6217-6222 and EBA_v6224-622; EBA_v6230 validation rules (warnings) are correctly implemented and should be applicable for all institutions?

  • 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_4640
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Benchmark Rates of other currencies than EUR, USD, GBP

Can you kindly confirm: - Currencies other than the three currencies mentioned in Point 3(b) namely EUR, USD and GBP must be compared to the benchmark in the same currency - For currencies that are not captured by LIBOR (e.g. CAD, RON), we should apply the benchmark rates set by the respective organisation (e.g. Romania Three Month Interbank Rate for RON).

  • 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_4616
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

FINREP F01.03, F02 and F46 checks (V1226_m and V0786_m)

The non-xbrl check V1226_m is in contradiction with v0786_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: 2019_4612
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Validationrule v5713_s DPM2.8 FINREP F 46.00

Our question relates to EBA validationrule v5713_s which, in our view, is not always applicable. This validation rule applies to the situation where a dividend distribution is done from "Capital"; the first column. In this situation the amount of dividend should be negative in c_010, r_110 of template F46.00. However, there can also be the situation that a stock dividend is converted from Share premium to Capital. In this situation there is a negative amount reported in the second column "Share premium" and there is an equal positive amount in the column "Capital" disclosed. The total change in equity is nil, but there is a shift from Share premium to Capital. In this situation should it be possible to report a positive amount in the column "Capital". Is our understanding correct ?

  • 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_4591
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Reporting of contributions to the default fund of a CCP

There seems to be an incoherence between Q&A 2013_209 and the instructions contained in Annex 2 of EBA Implementing Regulation (EU) No 680/2014 regarding the Reporting of contributions to the default fund of a CCP.

  • 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_4563
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

[eba_v1042_m] f16.01

Why the total of the table F16.01.b doesn't follow the rule [eba_v1042_m]? Is this related to negative interest rates?

  • 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_4434
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Closely correlated currencies

How to manage the closely correlated currencies according to Article 354(1) CRR under the standardised approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4142
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 08/05/2020

ABCP Programme

Does an ABCP programme meet the definition under Article 242(9) of Regulation 575/2013 – or Article 242(11) CRR as amended by Regulation (EU) 2017/2401, which refers to-Article 2(7) in Regulation 2017/2402   when it invests not only in securitisation transactions (i.e. ABCP transaction as defined in Article 2(8) in Regulation 2017/2402) but also in other type of assets?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4324
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 08/05/2020