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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

Initial margin for the purpose of hypothetical capital calculation

What amount should be used as the initial margin posted by to the Central Counterparty (CCP) by a clearing member for the purpose of Article 50a of Regulation (EU) No 648/2012 (EMIR), introduced by Article 520 of Regulation (EU) No 575/2013 (CRR)? Does the Article 50b(c) of the EMIR apply to the initial margin? Should the excess initial margin be included?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1889
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 21/08/2015

Deferred Tax Assets and Liabilities related to the fair value reserves connected to gains or losses on cash flow hedges

In accordance with Article 33(1)(a) of the Regulation (EU) No 575/2013 of the European Parliament and of the Council (CRR), the institutions do not include the fair value reserves related to gains or losses on cash flow hedges in any element of Own Funds (as a result of the specific filter applied). Is it correct to not consider DTA / DTL related to the fair value reserves related to gains or losses on cash flow hedges in the net DTAs deductible from CET1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1887
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Consolidated Risk Retention

Pursuant to Article 405(2) of Regulation (EU) No 575/2013, can the retention requirements under Article 405(1) be satisfied on an EU consolidated basis where the securitisation is of exposures from one entity instead of several entities?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1886
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of own funds requirements for non-continuous options

Where do own funds requirements for non-delta risks related to non-continuous options have to be reported, if the institution applies the delta plus approach?

  • 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: 2015_1885
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Values pre or post conversion factors

Should institutions report in C 07.00 columns 160-190 a) the amounts of column 150 allocated to each conversion factor after or before the application of conversion factors?

  • 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: 2015_1884
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

Net long and short position in Column 30 and 40

What is the exact meaning of net long and net short position for the purpose of columns 030 and 040 ( 18net positions long / short 19) in template C 21.00 (MKR SA EQU)?

  • 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: 2015_1883
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/06/2016

Reporting on "collateral received" and "financial guarantees received" in columns 170 and 180 of template F 19.00

Should be included in columns 170 and 180 of template F 19.00 also collateral received on performing exposures with forbearance measures?

  • 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: 2015_1880
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Definition of "Refinancing" for the purpose of reporting in columns 040, 080 and 160 of template F 19.00

What is the appropriate definition of "Refinancing" for the purpose of reporting in columns 040, 080 and 160 of template F 19.00?

  • 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: 2015_1879
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Clarification of EBA answer published for Q&A 2014_1000

Q&A 2014_1000 states that there are only two accepted ways in FINREP to report interest income and expenses from financial instruments held for trading, interest income and expenses (“clean price”) or as part of the gains and losses from these assets (“dirty price”), and that for economic hedge there is the possibility to report the amounts separately as financial income or expenses.How should this answer be understood in the case of credit institutions applying “dirty price convention”? The possibility to report the amounts separately as interest income or expenses (mentioned in the last sentence of the answer) envisages only the items “Interest income. Financial assets held for trading” and “Interest expenses. Financial liabilities held for trading”?

  • 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: 2015_1878
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/03/2015

Validation rules v1906_h and v1907_h

Do validation rules v1906_h and v1907_h have to be modified?

  • 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: 2015_1877
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/06/2016

Treatment of stock futures under Article 390(3) and Article 327(1)

Does a short position on an equity future contract net off against a long position in its underlying equity, considering that the underlying security and the equity are identical, deliverable, quoted on an official exchange and cleared through the corresponding CCP?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1873
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 02/10/2015

Tier 2 instruments issued by a consolidated subsidiary non recognised by a third Authority

When applying Article 87 of Regulation No 575/2013 (CRR), should a Tier 2 instrument issued by a non-EU subsidiary (and subscribed by third parties) be included in the consolidated own funds of the EU-parent company insofar as this instrument is not recognised by the local non-EU Authority?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1872
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 04/03/2016

C 45.00 - LEVERAGE RATIO CALCULATION (LRCalc): arithmetic mean of monthly data vs. end of quarter data

According to Art. 429.2 CRR (old version), institutions shall calculate the leverage ratio as the simple arithmetic mean of the monthly leverage ratios over a quarter. This requirement is implemented in table C 45.00 in the current LR-reporting which is applicable as long as the new LR-reporting (currently under public consultation, applicable as of Q4/2015 at the earliest) is not yet in place. However, Art. 429 CRR has already been replaced by the delegated act on LR (already in place since 18 January 2015). Now, paragraph 2 of Art. 429 clearly states that “institutions shall calculate the leverage ratio at the reporting reference date” (i.e. only end-of-quarter leverage ratio). Against this background some of our reporting agents raise the question, whether they are still be obliged to submit the exposures on a monthly basis as of Q1/2015, even the new LR-templates are not yet in place.

  • 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: 2015_1871
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 12/06/2015

Risk weight for exposures to unrated institutions

Does Article 121 allow unrated institutions to be assigned government ratings only in the case of a government guarantee for the deposits of that bank? Additionally, does Article 121(3) apply to unrated institutions as well? Does it say that if we have a cash balance in an unrated bank we should assign a risk weight of 20%?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1869
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/12/2015

CR IRB template – inclusion of haircut exposure value

In what column of the Credit Risk IRB templates shall the increase of the exposure value by the haircut exposure value be reported (in column 090, in column 110 or just in column 255 and 260)?

  • 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: 2015_1868
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Disclosure of the Leverage Ratio

How shall institutions disclose the Leverage Ratio as set out in Art. 451 CRR and the Delegated Regulation (EU) 2015/62, entered into force on the 18 January 2015, while there is no adopted ITS on Disclosure until now?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1863
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 12/06/2015

Removal of Senior Management

We would like clarification on Article 28 of Directive 2014/59/EU (BRRD) envisaging the possibility to remove the senior management and also with regard to individuals. This seems the same power that is already envisaged in Article 27(1)(d) providing for the removal of managers that are unfit to perform their duties albeit linked to a different trigger; therefore different triggers could end up with the same early intervention measures.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1862
  • Topic: Early intervention
  • Date of submission:
  • Published as final Q&A: 17/04/2015

Counterparty credit risk add-on for repurchase transactions

Is it required to calculate and report this counterparty credit risk add-on also for cash borrowers in repo transactions or for the borrowers in securities lending transactions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1861
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 10/07/2015

When should an external rating be considered as a primary factor determining an internal rating assignment

Concerning the practical application of the RTS on materiality: When should an external rating be considered as a 'primary factor' determining an internal rating assignment, and by what measure is the relative importance of the different variables comprising an internal model for credit risk to be evaluated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2015_1859
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/06/2015