Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Calculation of the number of directorships held (privileged counting of mandates).

How should the mandates be counted in a situation where one person is an active board member in several connected (through IPS, group or qualified holdings) credit institutions and the privileged counting of mandates shows different results depending on the perspective from which the mandates are counted? Especially how the mandates should be counted where there is more than one notifying institution, in particular where the institutions are connected through qualified holdings? How should such a situation be resolved in cases where different competent authorities (in more than one Member State and / or the ECB) are involved?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4158
  • Topic: Internal governance
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Is a gradual reduction of the overdraft facility with a current account a forborne measure?

Should an exceeded overdraft facility, which is gradually reduced by the bank as stipulated in terms and conditions, be classified as forborne exposure even if the customer does not meet any criteria for default?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4346
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Validation rule on C_17.01 template - v5839_m

Is validation rule v5839_m 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: 2018_4259
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Validation rule on C_05.01 template - v4889_m

Is validation rule v4889_m 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: 2018_4258
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Is the validation rule for Finrep (DPM 2.7) v5510_m, correct?

Is validation rule v5510_m correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3975
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Pillar III templates aligned with the new supervisory reporting package, DPM 2.7

Should we adjust template EU CR2-A in order to facilitate the implementation of the EBA Guidelines on disclosure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2018_3941
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Validation rules v5434_m to v5447_m in DPM 2.7.0

Are validation rules v5434_m to v5447_m 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: 2018_3898
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Exposures in the form of covered bonds

Would the preferential treatment set out in Articles 129(4) and (5) and in Article 161(1)(d) be applicable to derivative instruments entered into in relation to covered bonds exposures, provided that the counterparty’s claims are secured by the same pool of assets as the covered bonds’ and rank pari passu with the claims of the covered bonds holders?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4328
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Identification and access for testing purposes of entities that are not authorised third party providers (TPPs)

How would account servicing payment service providers (ASPSPs) identify entities that have applied for authorisation as a TPP?Should ASPSPs offer access to their testing facility to entities that are not (i) authorised payment service providers or (ii) entities that have applied for authorisation as a TPP (e.g. technical service providers)? If the answer is ‘yes’, should ASPSPs offer the same level of service to the referred entities?

  • 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_4609
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Meaning of current year in validation rule v6167_m

What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2018_3934
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Reporting of exposures whose collateral type is (g) credit derivatives, (h) guarantees or (i) unfunded credit protection

How to report exposures whose collateral type is (g) credit derivatives, (h) guarantees or (i) unfunded credit protection?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2018_4091
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Category on which the covered part of exposures should be reported.

How to report the covered part of exposures under IRB approach ?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2018_4093
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

For swaps should we consider that we have a collateral agreement with the counterparty?

In the EBA ITS package for the benchmarking exercise, for swaps should we consider that we have a collateral agreement with the counterparty? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2018_4263
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

ASPSP is denied the waiver to the fall-back by an NCA

If an Account Servicing Payment Service Provider (ASPSP) is denied the waiver to the fall-back by a National Competent Authority (NCA) (i.e. at 13 September 2019), will the ASPSP still have 2 months to build the fall-back?

  • 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_4140
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 22/03/2019

Scope of application of the term "securitisation" and risk retention obligation in Article 405 CRR

Does the term ‘securitisation’ defined in Article 4(1)(61) of Regulation (EU) No 575/2013 capture loan origination, as opposed to loan acquisition, where the loan origination occurs over a defined period and is subject to the originated loans satisfying specified eligibility criteria, and is funded by the originator issuing tranched debt with the subordination of the tranches determining the distribution of losses during the ongoing life of the portfolio of originated loans?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3806
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 22/03/2019

Application of margin period of risk scalars for exposures to clients

Do the provisions laid out in Article 304(3)(a), Article 304(4) and Article 304(5) of the CRR, also apply to the calculation of the EAD for leverage ratio purposes?  

  • 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: 2018_3756
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/03/2019

COREP Template C 25.00.Validation rule v0641_m.

In 2014, our National Competent Authority has clearly mentioned in the validation of the internal model of KCVA computation, that our institution determines the KCVA using the standard method for the below transactions: - Transactions out of the internal model EEPE perimeter - Transactions which are part of the eligible perimeter but, due to data quality issues, the EAD has been calculated in standard method. This justifies that for a counterparty which has expositions calculated in both standard and internal methods, we will have an advanced and standard CVA charge. In the COREP CVA template, we should state the number of counterparties calculated in advanced method (r020) and in standard method (r030), the sum of all counterparties should appear in r010. Related to eba_v0641_m, we remove the duplicates between the 2 calculation methods to fill the r010, in order to avoid the double counting of counterparties for which we have both of STD & ADV CVA. Knowing the fact that we can have the both methods for a given counterparty, should we report strictly the sum of r020 and r030? Or should we continue to consider the r010 as the sum of counterparties that generate KCVA, disregarding the calculation method used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4146
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

COREP template C 05.01-validation rule v0269

Is it correct that the formula in COREP Table C 05.01, r100,c040 does not take into account the new cell r440,c040 (Adjustments due to IFRS 9 transitional arrangements)?

  • 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_4066
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Finrep validation rules of F 02.00 and F 16.01

In report F_16.1 the income is broken down by Derivatives - Trading ; Debt securities; Loans and advances and Other assets. In report F_02 the income is broken down by Accounting portfolio and Other assets so we believe rule v5598_i may not alwasy be true. The same logic is also for liabilities therefore rule v5601_i may not always be true.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4009
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 15/03/2019