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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

Risk weight of EURATOM debt

Which risk weight shall apply to outstanding/new EURATOM debt instruments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3204
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 14/07/2017

Application of the definition of ‘speculative immovable property financing’ under the Standardised Approach

In case the borrower is the developer of a real estate project for which future contract agreements with future owners have been signed about the properties under development, would this exposure fall within the scope of the speculative immovable property financing?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3173
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/09/2018

Documentary credits in which underlying shipment acts as collateral and other self-liquidating transactions

Does a documentary credit secured by an assignment, assignment for security and/or pledge of the underlying sales contracts with payment to be effected to an account pledged in favour of either the lender (i.e. L/C issuing bank) or the security agent (especially in case of a syndicate) satisfy the condition of Annex 1 (3) (a) (i) CRR that “the underlying shipment acts as collateral or that the transaction is otherwise self-liquidating”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3171
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/10/2017

Capital requirements for regular-way transactions during the settlement cycle

How shall regular-way transactions be treated during the settlement cycle, in particular where the settlement cycle is shorter than for long settlement transactions? Is the treatment of such pending settlement transactions different for trade date accounting vs. settlement date accounting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3155
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Speculative immovable property financing

Should the loans that banks grants to build a first home, as a part of the normal business process, where the repayment of the financing comes from the sale of the property to the first buyer, without a speculative purpose of resale, and on the basis of the credit risk valuation of the borrower’s financial strength, be considered as speculative immovable property financing under Article 4(1)(79) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3131
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/06/2017

Valuation of immovable property performed by statistical model

Does the reference to the independent valuer in Article 229(1) and Article 208(3)(b) of Regulation (EU) No 575/2013 (CRR), permit the recognition of a statistical model of property valuation, the outcomes of which are periodically verified by other independent valuer, as independent valuer?Does the reference to the independent valuer in Article 229(1) and Article 208(3)(b) CRR permit that before a credit decision, a property would be evaluated by a statistical model, the outcomes of which are periodically verified by another independent valuer, without additional confirmation by an independent valuer for each property valuation made by a model?Does the reference to the independent valuer in Article 229(1) and Article 208(3)(b) CRR permit that before a credit decision, a property would be evaluated by a statistical model, where outcomes of a model are periodically verified by another independent valuer, and there is an additional confirmation or correction for the each statistical valuation, after a credit decision by another independent valuer? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3078
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/05/2017

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

Use of bona fide estimates for the determination of the size of a corporation

Is it allowed to use bona fide estimates for the determination of the size of a corporation for the purposes of Articles 153(4) or 162(4) CRR (identification of SMEs) analogous to Article 4(3) of the Annex Commission Recommendation 2003/361/EC? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3049
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/06/2017

Capital requirements deduction for credit risk on exposures to SMEs

Further to Q&A 2135 and Q&A 2268, can the capital requirement deduction (SME factor) be applied for speculative immovable property financing (Corporates) if conditions determined in Article 501(1) and (2) of Regulation No 575/2013 (CRR) are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3012
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/10/2017

Risk weighting attributed to gold bullion coins

Are gold bullion coins included in the term ‘gold bullion’ as used in Article 134(4)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3011
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/04/2017

Prudential treatment of extraordinary ex-post contributions to resolution funds pursuant to Article 104 of the BRRD

Can the extraordinary ex-post contributions to resolution funds provided for by Article 104 of the BRRD be considered as any of the off-balance sheet items mentioned in Annex I of the CRR ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2985
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Treatment of an institution’s guarantees for investments into CIUs

In case of an institution’s guaranteeing the amount of a customer’s original investment into a CIU and a minimum yield:1. To which risk category for off-balance sheet items in Annex I CRR shall these guarantees be assigned, in particular shall this assignment depend on any risk mitigation techniques used by the CIU?2. Shall these guarantees be treated as an exposure in the form of units or shares in a CIU, which would in particular allow the institution to look-through to the underlying exposures of the CIU, provided the conditions for looking-through are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2971
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/10/2017

Implementation of default definition - retail portfolio

In the case of retail exposures, can the default definition be implemented in a way that the default of an exposure secured by mortgage extends to unsecured facilities, but not the other way round?Alternatively, should a bank implement the default definition within the retail non SME portfolio consistently at the level of facility, i.e. at the level of product type without extending the default to other facilities?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2968
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/05/2017

Other items

Does the approach specified in Article 134(5) CRR regarding the risk weight to be applied to assets purchased on a forward basis also apply to assets sold on a forward basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2935
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/04/2017

Contingent liabilities within the Merchant Services Industry

Does the contingent liability to which an acquiring bank is subject in the course of the merchant acquirer business qualify as an off-balance sheet item according to Annex I  CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2916
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/06/2017

Obligation to carry out analysis and to consult with EBA on planned increase of risk weights before RTS on this matter are finally adopted and published in the Official Journal of the European Union

Is there an obligation to carry out appropriate analysis and to consult with EBA on planned increase of risk weights since RTS on this matter are not finally adopted and published in the Official Journal of the European Union?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2894
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/02/2017

Standardised approach risk weighting

In the scenario below, if the repayment of a retail depends on the client's business (and not the performance of the property), could a loan secured by immovable commercial property have a higher RW than a similar loan which is unsecured?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2891
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Rating of subsidiaries

Is “separately rated” in Article 172(1)(d) to be interpreted as “rated on individual information” or as ”having own rating based on a separate rating process”? Alternatively put: How is “separately rated” in Article 172(1)(d) to be interpreted?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2864
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Items associated with particular high risk

Does the term "investments" in letters (a) investments in venture capital firms, (b) investments in AIFs (...) and (c) investments in private equity include only exposures in the form of shares or units in (equity of) venture capital firms, AIFs, and private equity, or it is related to all forms of exposures (e.g. debt and equity instruments, units and shares in CIUs, etc.)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2845
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022