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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

Immediate obligor and ultimate obligor concerning exposures secured by mortgages on immovable property

In ‘Annex II – Reporting on own funds and own funds requirements’ we find the following instructions:‘3.4. Credit and counterparty credit risks and free deliveries: Information with geographical breakdown (CR GB)The term ‘residence of the obligor’ refers to the country of incorporation of the obligor. This concept can be applied on an immediate-obligor basis and on an ultimate-risk basis. Hence, CRM techniques can change the allocation of an exposure to a country. (…) Data regarding ‘original exposure pre conversion factors’ shall be reported referring to the country of residence of the immediate obligor. Data regarding ‘exposure value’ and ‘Risk weighted exposure amounts’ shall be reported as of the country of residence of the ultimate obligor.’What does this mean for an exposure secured by mortgage on immovable property where obligor and immovable property are located in different countries?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2014_1354
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/07/2017

In the case of a repurchase of CET 1 instruments, AT 1 instruments, or T 2 instruments for market making purposes, competent authorities may give their permission in advance to reducing own funds for a certain predetermined amount.

Would such a frame given in advance to reduce own funds for a certain predetermined amount for market making purposes result in a deduction from own funds at the time when permission is given or would a deduction from own funds be made at the time when the actual repurchase of capital instruments takes place? It should be noted that the question being posed is linked to the situation where a permission is given in advance to repurchase own capital instrument for market making purposes. The question being posed is not linked to a situation where a permission is given in advance to repurchase own capital instrument in order to reduce own funds on a permanently basis.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2014_1352
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 31/10/2014

10 largest exposures to institutions and unregulated financial sector entities

How to count 10 largest exposures to institutions? If a reporting institution has 7 large exposures to institutions, does it have to include into report its next 3 largest (but "non large") exposures (10 alltogether) or 10 largest (but "non large") exposures (17 alltogether)? the same applies to reporting of exposures to unregulated financial sector entities.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1351
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 08/05/2015

LE reporting - reporting of exposures exempted under Article 400(1)(c) - exposures carrying explicit guarantees of central governments

What is the correct reporting of an exposure to company A if this exposure is guaranteed by the explicit guarantee by central government (this central government with 0% RW) - such exposure is subject to an exemption under Article 400(1)(c)?

  • 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: 2014_1349
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Interest Rate Cashflows due within 30 days

Are interest rate cashflows shown in the same position in the In-/Outflow-Template as the corresponding redemption cashflows? Are the weighting factors for interest rate cash flows the same as for redemption cashflows.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1340
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F 07.00: Validation Rules v0817_m, v0818_m, v0822_m, v0823_m, v0824_m

We assume that validation Rules v0817_m, v0818_m need to be corrected for F 07.00, column 110 and v0822_m, v0823_m, v0824_m for F 07.00, columns 080 and 090, because the sign >= does not work in this case for negative numbers. Can you please confirm?

  • 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: 2014_1331
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Large Exposures Reporting of Volatility Haircut applied to Exposure Value

The instructions for template C 28.00, column 300 and C 29.00, column 310 i.e. “(-) Funded credit protection other than substitution effect”, are currently unclear how volatility haircuts that are applied to the exposure value under CRM are reported.Some vendors have suggested that the CRM volatility haircut applied to the exposure value should be included as a positive value (+), while the volatility haircut applied to the collateral should be included as a negative value (-) within template C 28.00, column 300 and template C 29.00, column 310.This is the only way to satisfy the following validation rules:v0653_m{c330} = {c210} + {c240} + {c250} + {c260} + {c270} + {c280} + {c290} + {c300} + {c310} + {c320}v1683_m{c340} = {c220} + {c250} + {c260} + {c270} + {c280} + {c290} + {c300} + {c310} + {c320} + {c330}The current text used for “(-) Funded credit protection other than substitution effect”, in templates C 28.00 and C 29.00 simply states that "the institution shall report the amounts of funded credit protection, as defined in Article 4(58) of Regulation (EU) No 575/2013, that are deducted from the exposure value due to the application of Article 401 of Regulation (EU) No 575/2013". There is no reference to the volatility haircut applied to the exposure value under CRM. Therefore, can we suggest that the instructions to template C 28.00, column 300 and template C 29.00, column 310 are amended to provide clarification on how the volatility haircut applied to the exposure value under CRM is incorporated into the large exposures templates C 28.00 and C 29.00

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1327
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Classification of invoice discount facilities as full risk items

1. Should invoice discount facilities always be classified as full risk items or may such facilities be classified as medium/low or low risk if they may be cancelled with immediate effect when the assumptions used for setting the limit change? 2. Should the nominal value of an invoice discount facility as an off-balance sheet item be calculated as the difference between the contractual limits of the total credit volumes of clients and the amounts that have been paid to clients for the discounted invoices not yet due for payment from customers?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1324
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/10/2014

Conditons to be fulfilled when netting positions in market risk of third countries

According to Article 325 (3) letter b CRR undertakings located in third countries have to comply, on an individual basis, with own funds requirements "equivalent to those laid down in this Regulation". To assess whether this condition is fulfilled by the third country institution, is it sufficient for the institution to look only on Article 92 CRR, or has the assessment to be based on e.g. Article 25, 51 et seq., 63 et seq, 102 and 325 CRR or even on the CRR as a whole? In particular, is there a relation to the Commission´s delegated act on third country equivalence that will be issued by the end of 2014? Once the delegated act on third country equivalence is issued, will supervisors and institutions be able to treat exposures to the third countries mentioned therein as equivalent without effecting further analyses under Article 325 (3) letter b CRR? With regard to Article 325 (3) letter c CRR: what proof of evidence is deemed necessary to assess the fulfillment of this condition? Is this Article fulfilled if a lawyer located in the respective third country states that there is no regulation in place which might significantly affect the transfer of funds within the group? Does this opinion have to be given e.g. by a lawyer resident in the home country of the third country institution or the country of the institution wanting to apply Article 325 CRR or the third country regulator? As we are of the opinion that letter c is hard to be fulfilled (or rather evidence is hard to provide) we would like to understand the rationale behind this condition.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1323
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Calculation of the remuneration bracket

Could EBA clarify which categories of staff should be taken into account when the remuneration bracket is calculated?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 604/2014 - RTS Remuneration: criteria to identify categories of staff
  • ID: 2014_1321
  • Topic: Remuneration
  • Date of submission:

Reporting of positions in closely correlated currencies (CRR Art. 354)

Template C 22..00 (MARKET RISK: STANDARDISED APPROACHES FOR FOREIGN EXCHANGE RISK (MKR SA FX) wrongly assumes that any pair of currencies closely correlated (row 020) can only be two non-reporting currencies. In fact, one of them can be the reporting currency of the reporting institution. This requires change of the title of the aggregate row 010 as well of the common title of columns 060-080.

  • 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: 2014_1318
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Definition of "Other collateralized loans" in relation to validation rules between F 05.00 (r100) and F 13.01 (c030, c040)

Do credit institutions in row "of which: other collateralized loans" in the tables F 05.00 and F 07.00 include also loans and advances that are secured by received financial guarantees or other guarantees? Final draft ITS on supervisory requirements in Annex V, Part 2.41 (i) for Tables F 5.00 states: “Other collateralized loans” include loans formally backed by collateral, independently of their loan/collateral ratio (so-called “loan-to-value”), other than “Loans collateralised by immovable property”, “Finance leases” and “Reverse repurchase loans”. This collateral includes pledges of securities, cash, and other collateral."

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1309
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/01/2016

AE-COL (F 32.02), AE-MAT (F 33.00).

1) Meldebogen AE-COL: Nach unserer Auffassung sind nur solche Sicherheiten relevant, die im Groß- und Interbankenhandel Anwendung finden. Sicherheiten in Privatkundendepots werden dabei unberücksichtigt. Ist diese Annahme richtig? Beispiel: Die Bank gewährt dem Kunden einen Wertpapierkredit, damit er Wertpapiere erwirbt. Der Kunde verpfändet diese Wertpapiere dann als Sicherheit. Sind diese als erhaltene Sicherheiten zu berücksichtigen? 2) Meldebogen AE-MAT: Die gestellten Sicherheiten müssen mit den Restlaufzeiten der zugrunde liegenden Transaktionen gemeldet werden. Auf der Passivseite sind für unser Institut hunderte von Geschäften relevant. Soll dabei die Restlaufzeit jeder einzelnen Transaktion berücksichtigt werden oder ist eine Durchschnittsrechnung der Laufzeit bzw. pauschale Anrechnung im letzten Laufzeitband ausreichend? Beispiel: Die Bank refinanziert sich über Refi-Darlehen. Hunderten von Darlehen steht ein Wertpapier als Sicherheit gegenüber. Soll der Wert des Papiers proportional auf die Restlaufzeiten der einzelnen Darlehen aufgeteilt werden oder ist eine Ermittlung der Durchschnittslaufzeit ausreichend?1) AE-COL template (F 32.02): in our view, only collateral used in wholesale and interbank trading is relevant. Collateral in private customer portfolios is thereby not takeninto consideration. Is this assumption correct?For example, the bank grants the customer a loan against securities so that he can acquire securities. The customer then pledges those securities as collateral. Are they tobe taken into consideration as collateral received?2) AE-MAT template (F 33.00): the collateral posted must be reported with the residual maturities of the underlying transactions. On the liabilities side, hundreds of transactionsare relevant for our institution. Should the residual maturity of each individual transaction be taken into consideration or is an average maturity calculation or an overall imputationin the final maturity band sufficient?For example, the bank refinances its operations using refinancing loans. Hundreds of loans are covered by one security as collateral. Should the value of the security becredited pro rata to the residual maturities of the individual loans or is it sufficient to determine the average maturity?

  • 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: 2014_1306
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/06/2021

Difference between and Annex I/ Annex II/1.6 description and DPM descrption of the same table name

There is a difference regarding the name of table C 05.02 Capital Adequacy, between Annex I sheet C 05.02/ Annex II Own funds paragraph 1.6 and DPM Database/ DPM Table Layout. While in Annex I/II name is 'Grandfathered instruments: Instruments NOT constituting State aid (CA5.2)' in DPM Database/DPM table layout, namie is 'C 05.02 - Capital Adequacy - Transitional provisions: Grandfathered instruments constituting State aid'. Please confirm what name is correct and should be used for table C 05.02 Capital Adequacy related to Grandfathered instruments (with NOT or without 'not').

  • 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: 2014_1305
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Material exposure in connection with term "days past-due" in the definition of non-performing exposure

What is the reading of the term "material" exposure in connection with "days past-due" for the purpose of definition of non-performing exposure?Can the "materiality threshold" be applied in a way that the counting of days past due starts when the past-due amount of the whole exposure of the obligor exceeds pre-defined materiality threshold?

  • 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: 2014_1297
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Memorandum Items in Credit Risk SA

Can you please confirm that the memorandum items in row 290-320 only should 1. Include Exposures secured by immovable property under articles 124,125 and 126 2. In case of the exposure being to a "High Risk" customer that is fully secured by an eg. RRE then the in template C 07.00 - exposure class "High Risk" no memorandum items will be completed (based on point 54 of the instruction as High Risk Category is not one of them) BUT instead the original asset class of the high risk obligor eg. Corporate should be completed

  • 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: 2014_1295
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Reporting of significant currencies (> 5%) according to Art. 415 (2) lit. a CRR

XBRL taxonomy requires the "total” of all currencies plus a breakdown for each "significant currency". This lead us to the following questions: 1) What is the definition of “total”? 2) Has the reporting currency itself (which will be in any case greater than 5%) to be reported separately as “significant currency”?

  • 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: 2014_1294
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 08/04/2016

Classification of institution in LR5

What should be reported in {LR5;040;1} in case of brokerage houses?

  • 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: 2014_1287
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Supplementary Reporting

In templates C51.00 to C53.00, which criteria should be applied to determine the items subject to Supplementary Reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1272
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 24/01/2022

Incorrect legal references

Which are the correct legal references of the item in row 020 of template Grandfathered Instruments: Instruments not Constituing State Aid (C05.02)?

  • 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: 2014_1269
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016