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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.

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List of Q&A's

Application of the exemption for transactions to trusted beneficiaries to Face-to-Face transactions

May the exemption for transactions to trusted beneficiaries (‘white-listing’) set out in Article 13 of Regulation (EU) 2018/389 (RTS on strong customer authentication and secure communication) apply to face-to-face transactions?

  • 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_4056
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/09/2018

Recalculation of thresholds of Article 48 CRR due to IFRS 9 transitional arrangements (Art. 473a)

Do the thresholds of Article 48 of Regulation (EU) No 575/2013 (CRR) have to be recalculated in the context of Article 473a(7) as well, taking into account the amounts added back to CET1 due to the application of Article 473a?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3784
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 24/08/2018

Investment firms’ exposures to credit institutions

Should MIFID investment firms which are subject to the CRR calculate the credit risk requirement for the clients’ funds (i.e. cash) deposited in a credit institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3422
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Reporting of Assets received as collateral in GC pooling transactions

When a financial instrument is received as collateral in a GC pooling transactions which allows participants to refinance the collateral through transactions with Central Bank or with other transactions in the same market, is the above-mentioned financial instrument eligible for the liquidity buffer under Article 7 LCR DA conditions?

  • 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_3741
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Reporting of cash flows related to collateral management transactions in which collateral to be delivered/received is defined using the participants netting exposure

If a credit institution has two repo/reverse repo trades of the same size, same basket, different positions and different maturities (one within 30 days and the latter maturing after 30 days horizon) with a CCP which requires for collateral exchange on a net basis, how should these operations be represented in LCR?

  • 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_3745
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

General and specific credit risk adjustments

Can a Supervised Entity not recognise changes in impairments, value adjustments or provisions in the calculation of the exposure value and thus avoid the deduction of these amounts from CET1?Or in case a Supervised Entity has changes in impairments, value adjustments or provisions, are these amounts automatically labelled as general or specific credit risk adjustments and shall therefore be accounted for in the calculation of the exposure value of an asset and deducted from CET1? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2017_3330
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Computing the amounts mentioned in Article 473a(2)(b) CRR, in case of the credit-impaired financial assets measured at amortised cost.

Should the amounts mentioned in Article 473a(2)(b) of Regulation (EU) No 575/2013 (CRR), as modified by Regulation (EU) No2017/2395 be:the total IFRS 9 Expected Credit Loss at transition date - point (i) and the amount of IAS 39 impairment losses at the day before transition date – point (ii), in case where there’s no modification regarding the reporting of the credit-impaired financial assets’ gross carrying amount (IFRS 9 vs IAS 39);the total adjusted IFRS 9 Expected Credit Loss at transition date - point (i) - see details below - and the amount of IAS 39 impairment losses at the day before transition date – point (ii)or the total IFRS 9 Expected Credit Loss at transition date - point (i) and the adjusted amount of IAS 39 impairment losses at the day before transition date – point (ii) – see details below, in case where the reporting of the credit-impaired financial assets’ gross carrying amount is modified (IFRS 9 vs IAS 39).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3781
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Calculation of the sf factor as per Article 473a(7)(b) of Regulation (EU) No 575/2013 (CRR)

Please clarify whether "RAsa" which is used for the calculation of the “sf” factor, as per Article 473a(7)(b) of the CRR, should be gross or net of tax

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3783
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 03/08/2018

IFRS 9 Transitional arrangements - Definition of ‘t’

How should “t” which is used in the formulas in paragraph 1 of Article 473a CRR be calculated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4113
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Validation rule v5548_h (FINREP template F 11.01 IFRS 9)

The validation rule v5548_h requires for template F 11.01 FINREP for all columns (010/020/030/040) row 460 (Cash flow hedges needs to be >= row 480 (Portfolio Fair value hedges of interest rate risk). Both amounts are part of the Derivatives Hedge accounting but there is no link between row 460 and 480. Can you delete validation rule v5548_h?

  • 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_3770
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Column 100 of the C 25.00 - CVA RISK template

Should OTC derivatives counterparties that have Zero EAD and hence Zero CVA charge be included in the count of counterparties required to be reported in template C 25.00, column 100.

  • 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_3754
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

How to report data in c230 and c240 of C 07.00

In EBA /ITS/2017/01 published 07 April 2017, c230 and c240 of C 07.00 are sub categories of c220. If the RW applied is based on uniform treatment paragraphs rather than an ECAI e.g. Article 119(2) of Regulation (EU) No 575/2013 (CRR) , should these RWA be included in column 230 & 240 of COREP C 07.00 even if they do have an own ECAI or could have applied the sovereign rating. e.g We have an exposure of 1000 in GBP to a Regional Government incorporated in UK for which a 20% RW is applied according to Article 115 (5) of the CRR. Additionally this exposure could attract a 20% RW by applying the sovereign rating. Based on the example do we include the RWAs of 200 GBP in column 240?

  • 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_3748
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Template 17 for a financial conglomerate , that elects that none of its entities operating in the insurance sector apply IFRS 9 for financial years beginning before 2021.

How shall a financial conglomerate as defined in Article 2(14) of Directive 2002/87/EC which adopts the deferral of the application of IFRS 9 for its entities operating in the insurance sector (Article 2(8)(b) of the Directive) should fill in template 17 ‘Reconciliation between accounting and CRR scope of consolidation: Balance Sheet’ (in particular, templates F 17.01 and F 17.03), as both financial assets and financial liabilities of the controlled insurance companies will continue to be classified according to IAS 39 and not to IFRS 9?

  • 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_3596
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Under Substitution Approach, How to report the covered part of the exposure where collateral is Covered Bond.

How shall the covered part of the exposure be reported where the collateral is a Covered Bond?

  • 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_3592
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/07/2018

SCV file test requirements by 3 July 2019

Does "formal routine checks" of SCV files in Article 96 refer to all indicators in paragraph 70 i1-i4? If so, are DGSs required to test all indicators by sampling files from all affiliated credit institutions by 3 July 2019?

  • Legal act: Directive 2014/49/EU (DGSD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/10 - Revised Guidelines on stress tests of deposit guarantee schemes under DGSD (repealing and replacing EBA/GL/2016/04)
  • ID: 2018_3738
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 27/07/2018

Funding Reliances - Table 2A1 - Insured and unsinsured deposits and uninsured deposit-like financial instruments (P 02.01)

Which of the following amount should "Deposits covered by a Deposit Guarantee Scheme according to Directive 94/19/EC or an equivalent deposit guarantee scheme in a third country" definition include: (1) Covered Deposits as per Art. (2) of the European Directive 2014/49/EU on Deposit Guarantee Schemes i.e. all deposits eligible for compensation for each customer with the credit institution up to €100.000 for each depositor. OR (2) Payable amount i.e. all deposits eligible for compensation for each customer with the credit institution after setting-off any credit institution's counterclaims against that specific customer and taking into account the maximum amount of compensation that is €100.000 for each depositor.

  • 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: 2017_3255
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 15/06/2018

Reporting of funding, obtained to supply credit to the real economy, and validation rule v4137_m

Should in table P 02.02, row 030, only the obligations be reported, which arise through the issuance of debt securities or is the reporting of loans from multilateral financial institutions and public financial institutions expected as well?

  • 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: 2016_2568
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 15/06/2018

Original maturity for off balance sheet items

How is the "original maturity" identified for items in CRR Annex 1 (2)(b)(ii)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3366
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 08/06/2018

Multiplier of 1.25 to the asset value correlation

In case of an exposure to a regulated financial sector entity which does not meet the requirements to be treated like a large financial sector entity (with total assets of less than 70 billion of euros), but which is owned by a regulated large financial sector entity which meets those requirements, does the multiplier of 1.25 to the asset value correlation apply for that exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3057
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 08/06/2018