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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.

List of Q&A's

Row 0820 of C 04.00

Row 0820 of C 04.00 - Own funds requirements related to Pillar II adjustments states that if a competent authority decides that an institution must calculate additional own funds requirements for Pillar II reasons, those additional own funds requirements shall be reported in this row. Two approaches could be considered:This row shall only be reported when Pillar II adjustments have been established as an amount instead of a ratio. This row shall always be reported:If Pillar II adjustments have been set as a ratio the amount to be reported is: P2R*RWA.If Pillar II adjustments have been set as an amount that figure shall be reported in row 0820 of C 04.00. Therefore, instructions do not establish which additional own funds requirements shall be reported.  Thus, which approach shall be followed to report row 0820 of C 04.00? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Part 2 – Template specific instructions to template B_06.01

Data point B_06.01.0050 is missing from the official ITS templates. Is this data point no longer applicable?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Template specific instructions – primary keys

How to report data fields in case of missing values?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0130 where the ICT service is not supporting a critical or important function considering that according to the data model this data field is a primary key?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Template specific instructions - field B_01.02.0060 (LEI of the direct parent undertaking of the financial entity)

What should be reported in case the financial entity does not have a direct parent undertaking (for example, is the parent undertaking itself) or reports the register on an individual basis?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Template specific instructions – field B_01.02.0050 (Hierarchy of the financial entity within the group)

What does ‘where applicable’ mean in the title of data field B_02.01.0050?  What should be reported in this field in case the entity that is being reported in this template is not a financial entity (i.e., option 22, 23, or 24 was selected in field B_01.02.0040 for the entity type)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

4.0 Reporting Framework - COREP_OF C02 Template

Could you kindly clarify if, in the context of map C02 , the comparison should be made with line 0036 instead of line 0010, considering that the output floor is calculated at the consolidated level and not at the contract level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

DPM 400 - Modelisation of report C1000

we have a suspicion of schizophrenic modeling on the new C1000 report.  Indeed on this report when we look at the annotated templates it seems that all cells from column 0090 are sharing the same XBRL address as their corresponding cell for the same row from column 0100. Which means that from a technical point of view we will only be able to submit one “amount” per pair of cells C0090/C0100 for a dedicated row. For instance the Annotated templates stats that : {C_10.00, r0060, c 0090, s0000}=={C_10.00, r0060, c 0100, s0000} VariableID 3295841 VariableVID = 3295841    In the same time when we look at the ITS : We understand that may be possible that the transitional provisions do not apply  and so that or instance amount reported in cell 0020 _ 0090 can be equal to the amount in cell  0020 _ 0100 where the amount expected  for both cell is zero.  But we do expect from our understanding of the ITS that the transitional provision may apply and that the impact should be reported in various rows. In this case we will need to report different amounts on a specific row for those two columns, which seems unfeasible with the current setting.   Do you agree with our understanding?    

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

C01.00 - CIU deduction from own funds

Where in the sheet C01.00 of the COREP, can we deduct CIUs under fallback approach (subject to 1250% RWA) from CET1 (as permitted by article 36.1.k.vi) since no dedicated caption is currently foreseen?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

breakdown of total exposures by risk weights

How should exposures subject to a risk weight of 70% according to Art. 126 (2) CRR3 be reported in the ITS on supervisory reporting v4.0? Should these exposures be included in the row r0280 “other risk weights” of the template C 07.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Definition of default for open-end investment funds

Should an open-end investment fund be considered an obligor under Art. 178 (1) CRR, irrespective of whether it has legal personality under a Member States’ regulations on investment funds?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Fair value hierarchy: Financial instruments at fair value (F14)

Can you provide more guidance on the amounts to be reported for “Change in fair value for the period” and “Accumulated change in fair value before taxes” in particular for derivatives falling under netting agreement and recognized with accounting offsetting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

MREL-REPORTING OF THE IMPACT OF GENERAL PRIOR PERMISSION

With reference to the Q&A 6852, we kindly request clarification on the appropriate logic to utilize when adding the amounts of the unused portion of the GPP for the rows in Template M 01.00, specifically rows 0250 to 0290. We would greatly appreciate if you could provide guidance on the correct allocation of the unused amount for rows 0260, 0270, 0280, 0285, and 0290. Given that the GPP has a duration of one year, it is our understanding that the unused amount should be accounted for solely in rows 0250 and 0285, as per convention.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL

Definition and scope of Asset Under Management

Are assets for which the investment firm provides generic advice services (outside of the MIFID authorisation scope)  to be included in the K-AUM calculation?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Other commitments received - calculation of guarantee amounts

On report F09.02, banks are asked to report guarantees received as collateral, partly in column 0010 and partly in column 0020. Where some questions have been answered in earlier Q&As, some questions remain: Based on Q&A 2013_214, guarantees received on off-balance sheet exposures should be reported as "Other Commitments Received". These are reported in F09.02 Col0020.Based on Q&A 2023_6773, in F09.02 Col0010, guarantees are considered by ignoring other collaterals.Should other collaterals be considered in calculating the amount reported in column 0020? Along the same lines, how should calculations work for both columns 0010 and 0020 if multiple guarantees are received? Within the same group of exposures and its/their contractually linked collaterals/guarantees, should they all be calculated separately and independently, ignoring the existence of other guarantees within the same group similar to the way other collaterals in the same group are ignored?The ITS states that "For other commitments received, the nominal amount shall be the total amount committed by the other party in the transaction." is to be reported in column 0020.  Does this also apply in the case whereby a guarantee is received to secure an (off-balance) exposures? In other words, should it be capped at the Off-Balance Exposure Amount or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions