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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

Validation rule v6063_m in v2.7.0.1

Is validation rule v6063_m: [F 20.04] sum((F 20.04, r040, c010, (sNNN))) = sum((F 01.01, (r070, r093, r097, r110, r142, r172, r176), c010)) correct? Why are r235 and r390 (F01.01) not present in this validation rule?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Validation rule v2818

Is there is an error in validation rule V2818 (check between AE and FINREP CON)? It caused a blocking error on the side of our institution. ERROR : v2818_m: sum({F 32.01, r070, (c010, c060)}) = {F 04.01, r080,c010} + {F 04.02.1, r070,c010} + {F 04.02.2, r080,c010} + {F 04.03.1, r070,c010} + {F 04.04.1, r030, c010} + {F 04.06, r080, c010} + {F 04.07, r080, c010} + {F 04.08, r080, c010} + {F 04.09, r030, c050} + {F 04.10, r080, c010} : [F 32.01: 22693164316; FINREP: 734022053; 596916000; 0; 11242205575; 10104104910] It checks debt securities issued by central banks and general governments. Apparently in the control some FINREP cells for central banks are missing. For example: {F 04.01, r070,c010} {F 04.03.1, r060,c010} {F 04.04.1, r020, c010} I see no reason why these fields are missing in the rule.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

DPM2.7.0.1 validation rules v5228_m,v5229_m,v_5231_m,v5235_m across template F18.00a, F04.04.1

v5228_m,v5229_m,v_5231_m,v5235_m: We found these validations do not take into account the expect credit loss amount calculated for other demand deposits and cash balances at central banks.  Are they 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)

Clarification “Other collateralized loans” template F 05.01

Should “Finance leases” and “Reverse repurchase loans” be excluded from the specification in row 100: “of which: other collateralized loans” in template F 05.01?

  • 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)

Validation rules on template F 18.00 comparing with F 04.04.1 and F 01.01

In the validation rules v2776_m the balance from F01.01 row 040 Other demand deposits is added. In the validation rules v3028_m/v3031_m/v3035_m row 040 Other demand deposits is not added. In these validation rules the Impaired amounts in template F 18.00a are compared to the Stage 3 amounts in template F 04.04.1 (excluding 040 other demand deposits). Is this correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

IFRS 9, validation rule v2776_m

Validation v2776_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. 

  • 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)

Template F 16.01 - Interest income and expenses by instrument and counterparty sector

Template F 16.01 requires that interest income and expense for hedging derivatives that hedge interest rate risk are recorded separately in row 250 column 010 and 020. These amounts are hedging the interest income or interest expense for other items recorded in the same column. For example, an interest rate swap can be used to hedge an AFS debt security. Whilst the AFS debt security in row 020 column 010 has a positive amount the interest on the swap can be negative in row 250 column 010. This negative amount should be presented in interest income so that total interest income is disclosed correctly. Similarly in column 020 if a swap is used to hedge interest rate risk on a deposit the interest would be negative. Again this needs to be reported in interest expense to ensure total interest expense is disclosed correctly.EBA v3950_s and v3951_s signage validation requires positive amounts in row 250. Please can EBA advise on whether FINREP can permit negative amounts in row 250 for columns 010 and 020.

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

Template F 16.01 - Interest income and expenses by instrument and counterparty sector

Template 16.01 requires the interest to be broken down by interest income and expense and also by financial instrument. Institutions use derivatives to manage financial instruments designated at fair value. For those that do not qualify for hedge accounting they act as an economic hedge with changes in the fair value of the hedged item. Typically, derivatives are used to manage fair value movements of debt securities issued, which are designated at fair value. One part of this economic hedge is the recording of net interest income. In IFRS the derivative interest income is netted within interest expense against the debt security issued as these balances are managed together. As FINREP requires the interest to be split out by instrument there would be a negative derivative expense. This negative amount should be presented in interest income so that total interest income is disclosed correctly in row 270. However the amount in row 010 column 020 would cause EBA v3951_s signage validation to fail as it requires a positive balance. Please can EBA advise on whether FINREP can permit a negative derivative expense for derivatives (row 010, column 020).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Calculation of fraud rates in relation to Exemption Threshold Values (ETVs)

Is it acceptable to calculate the fraud rate for the application of the TRA exemption per ETV band?

  • 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

Exemption from strong customer authentication (SCA) for payment account information in combination with accessing account information online in web browser

Is it acceptable to abstain from applying the 5-minute-rule when the strong customer authentication (SCA)-exemption for payment account information is in use?

  • 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

Exemptions from Strong Customer Authentication (SCA): trusted beneficiaries

Should a Payment Service User (PSU) recreate a list of trusted beneficiaries that was already approved in accordance with the EBA Guidelines on the security of internet payments?

  • 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

Access by AISPs when customer not present up to 4 times in a 24 hour period

Is the intention that the '4 times in 24 hour period' is implemented based on 4 sessions for access for account information per consented customer account, or 4 Application Programming Interface (API) calls (where APIs are used for the decicated interface) for account information, or another basis?

  • 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

Signature performed on the screen of a digital device as a factor in a two-factor SCA

Could a signature performed on the screen of a digital device 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

Consent for the provision of PIS and AIS

Could the consent to Account Information Service Providers (AISP)/ Payment Initiation Service Provider (PISP) to provide services to a Payment Service User (PSU) also be revoked by the bank directly for PSU’s ease of use and could ASPSPs offer the PSU to generally “opt out” of being able to use the services of bank-independent Third Party Providers (TPPs)?

  • 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

Large exposures - treatment of connected clients principle on exposures to other group entities outside prudential scope of consolidation

What treatment is envisaged in the context of connected clients for multiple exposures to multiple entities that are part of the same economic group, but are not included in the scope of prudential consolidation? Are these considered to be an exposure to the same (connected) client?

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

Credit Risk on Gold Bullion

Under Article 134(4) CRR, what would the risk weight be if gold bullion is held on our behalf by other institutions and where such investment is not backed by gold bullion liabilities?

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

Reclassification of own funds instruments from a grandfathered category to a fully eligible category and purpose of grandfathering provisions

Is it permissible for an institution, and if so under which circumstances and/or criteria, to reclassify own funds instruments from a grandfathered category to a fully eligible category in particular in a context where no change in the relevant applicable laws or terms and conditions of the reclassified instruments has taken place before the reclassification? Would the answer be the same for a reclassification of own funds instruments from a disqualified category to a fully eligible category?

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

Operation and security risk assessment of a branch of a credit institution

Does a branch of an EU credit institution operating in another Member State have to prepare separate assessment for its payment related activity and if yes which competent authority shall be responsible for receiving the assessment - is it the competent authority of the host or the home Member State?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/04 – Guidelines on ICT and security risk management - repealing EBA/GL/2017/17

Applicability of exemption from strong customer authentication (SCA) under Article 17 for card payments

Is Article 17 of Regulation (EU) 2018/389 applicable for the payer’s Payment service provider (PSP) for card-based payments?

  • 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