Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Realization of developers' collaterals and re-classification of developers into performing status

Clarifications are requested surrounding the classification of a borrower into default status and therefore into non-performing status, when the borrower is a developer / construction company and hence relies on the realisation of collaterals to repay his loans.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_3747
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

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

Reporting of forward starting transactions

Annex XXV Reporting on Liquidity Coverage Ratio defines remarks regarding settlement and forward starting transactions. The only forward starting transactions taken into consideration are forward repos, forward reverse repos and forward collateral swaps that start and mature within the LCR’s 30 day horizon and that are entered into subsequent before the reporting date. The Q&A 2014_784 published in 2014 seemed to identify a wider definition of relevant forward transactions for the LCR than the Annex XXV does some time after.  Should we limit our definition to Annex XXV one, or other forward start transactions are relevant for LCR if these two conditions are valid: •         are contractually fixed, but not yet settled at reporting date; and •            imply an in- and/or outflow of cash and/or liquid assets in the next 30 days? In this case, how should we report forward starting purchase or own issuance? If contractually fixed, forward starting transactions generating inflows or outflows are treated symmetrically for LCR or Article 32 par 7 introduces asymmetry?

  • 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_3744
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

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 template C17.01

1) Should all loss adjustments regardless of the Date of Occurrence of the original loss event be reported?2) For the rows relating to "Loss adjustments relating to previous reporting periods" (rows x40), should the adjustments be subject to materiality thresholds? Can the threshold used for registration of losses be applied also to loss adjustments?3) How should grouped losses split across multiple business lines be reported on row 910 "Number of events (new events)"? In case the loss is reported on multiple business lines, the row 910 will be lower than the sum of loss events reported on individual business lines.

  • 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_3740
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Location of the obligor for the calculation of the countercyclical capital buffer

What is the definition of “actual place of administration” in Article 1(4) of Regulation (EU) 1152/2014?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1152/2014 - RTS on the identification of the geographical location of relevant credit exposures for institution-specific countercyclical capital buffer rate
  • ID: 2018_3739
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 11/10/2019

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

Exempting foreign currency - denominated required minimum reserves according to Article 493(7) CRR

How is the level of exposures to central bank, in the form of Euro-denominated required minimum reserves in non-Euro Member States, determined for the purposes of Article 493(7) of Regulation (EU) No 575/2013 (CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3737
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Leverage ratio methodology - Art. 429(6) and (7) of Reg.(EU) No 575/2013 and Art. 429 a) of the Del. Reg. 2015/62 - art. 5 par. 3 of Comm. Deleg. Regulation (EU) 2015/63

To fill in some parts of the SRF 2018 Ex ante contributions Reporting forms in line with the Commission Delegated Regulation (EU) 2015/63, in particular the section related to “Derivative adjustment” (Art. 5 par 3), institutions must apply the “leverage ratio methodology” as defined in art. 429 of regulation 575 (CRR) to derivatives recognized in accordance with Article 295, where the current market value of the derivatives is negative. Are the variation margins paid in cash to the counterparty (a receivable asset) deductible from the net negative current market value (liability) of derivatives, based on the instructions contained in par. 3 of Article 429 a) of the delegated regulation 2015/62?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2018_3732
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

On demand secured lending of Level 1 assets

Can Level 1 assets that are used for on demand secured lending transactions be considered as liquid assets for the Liquidity buffer?

  • 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_3730
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Treatment of Value Added Tax (VAT) accounts opened for collection and payment of VAT

Should the Value Added Tax accounts be treated as operational deposits and should they receive the treatment mentioned at Article 27(1)(c) from Delegated Regulation (EU) 2015/61?

  • 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_3726
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 18/01/2019

COREP template C13: Consistency of the control v0530_m

COREP template C13: Is the EBA taxonomy control v0530_m consistent when tranches are deducted from own funds?

  • 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_3724
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

2.7 - Incorrect rules v0985_m and v0986_m

Validation rules v0985_m and v0986_m are incorrect in the taxonomy 2.7.0.1. They refer to columns 022 and 025 however these columns are greyed in the template F 20.04.

  • 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_3723
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/10/2018

Reporting of balances denominated in renminbi CNY and CNH in C22 MKR SA FX

In C22 MKR SA FX, where a bank is permitted to hold positions denominated in CNY and CNH, should CNH balances be combined with CNY balances in Row460, or included in Row470 under Other currency positions on the basis that CNH has its own readily-verifiable exchange rate and exposure against the reporting currency? For C22 Row020, if CNH balances are reported in Row470, should CNH be included in List of Closely correlated currencies against the Chinese Yuan (CNY) in Annex 1 to ITS ON CLOSELY CORRELATED CURRENCIES UNDER ARTICLE 354(3) OF REGULATION (EU) 575/2013?

  • 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_3720
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation Error arising from Guidance Notes for C 18.00 report

Which one should take precedence:(1) the general remarks for template C 18.00 in the ITS on Supervisory Reporting (Annex II), or(2) the existing formatting for the currency sheets of template C 18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2018_3718
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/04/2018

Reporting of financial asset sales and write-offs in FINREP template F 02.00

How should financial asset (e.g. loan portfolio) sales and write-offs be reported in the template F 02.00 (Statement of profit or loss)?

  • 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_3716
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Fair value changes due to changes in cross-currency basis spread eligible for CET1 capital (cost of hedging)

Are fair value changes due to changes in cross-currency basis spreads recognized in ‘other comprehensive income’, as referred to under IFRS 9 as the ‘cost of hedging’, eligible for CET1 capital under the CRR regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3715
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

EBA COREP Validation Rules on C 05.01

Row 140 column 060 is required to have a value that is less than or equal to zero. That is specified by validation rule v5016_s. In addition, the value in row 140 column 060 includes data entered into row 380 col 060. Were the value in the latter cell entered as a large positive, it is possible that the resulting figure in row 140 column 060 would be positive. Should there be a constraint placed on the value in row 380 column 060?

  • 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_3709
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Validation rule v4792_m, C 12.00 - Securitisations

In C 12.00.a, the validation rule v4792_m is (r030;040;050;060;070;080;090)] {{c050}} <= {{c010}} Since row 30 (ORIGINATOR: TOTAL EXPOSURES) represents the totals for Originators, the above might not hold true in cases where significant early amortization exposures are present. This is because the row 100 for early amortization is greyed out for the columns 010 to 040 in the report template and hence is not considered in row 030 for these columns. However, row 100 is not greyed out for the column 050 where the validation check is applied.

  • 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_3705
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 18/05/2018

Question on CSD capital requirements and investment policy

For collateral to be considered of the best quality for the purpose of CSDR Articles 59(3)(d) and 59(4)(d), debt instruments are required to be liquidated “on a same day basis”. In the same manner, the appropriate timeframe in order to access the asset under the investment policy, as provided by art. 82(2), should be “on the same business day” We ask European Authorities to clarify the meaning of “same day basis” and “same business day” and the settlement period linked to it.

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2018_3704
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 28/01/2022