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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

Meaning of current year in validation rule v6167_m

What is meant by “current year” in validation rule v6167_m? Does this date, 31-Dec-'current year-1', refers to Reference Date of filing report minus one year (e.g 31 Dec 2017 - 1 = 31 Dec 2016) or is the exactly current year minus one year ( e.g. 2018 -1 = 2017)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2018_3934
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Reporting of exposures whose collateral type is (g) credit derivatives, (h) guarantees or (i) unfunded credit protection

How to report exposures whose collateral type is (g) credit derivatives, (h) guarantees or (i) unfunded credit protection?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2018_4091
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Category on which the covered part of exposures should be reported.

How to report the covered part of exposures under IRB approach ?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2018_4093
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

For swaps should we consider that we have a collateral agreement with the counterparty?

In the EBA ITS package for the benchmarking exercise, for swaps should we consider that we have a collateral agreement with the counterparty? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2018_4263
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 29/03/2019

ASPSP is denied the waiver to the fall-back by an NCA

If an Account Servicing Payment Service Provider (ASPSP) is denied the waiver to the fall-back by a National Competent Authority (NCA) (i.e. at 13 September 2019), will the ASPSP still have 2 months to build the fall-back?

  • 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_4140
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 22/03/2019

Scope of application of the term "securitisation" and risk retention obligation in Article 405 CRR

Does the term ‘securitisation’ defined in Article 4(1)(61) of Regulation (EU) No 575/2013 capture loan origination, as opposed to loan acquisition, where the loan origination occurs over a defined period and is subject to the originated loans satisfying specified eligibility criteria, and is funded by the originator issuing tranched debt with the subordination of the tranches determining the distribution of losses during the ongoing life of the portfolio of originated loans?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3806
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 22/03/2019

Application of margin period of risk scalars for exposures to clients

Do the provisions laid out in Article 304(3)(a), Article 304(4) and Article 304(5) of the CRR, also apply to the calculation of the EAD for leverage ratio purposes?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2018_3756
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/03/2019

COREP Template C 25.00.Validation rule v0641_m.

In 2014, our National Competent Authority has clearly mentioned in the validation of the internal model of KCVA computation, that our institution determines the KCVA using the standard method for the below transactions: - Transactions out of the internal model EEPE perimeter - Transactions which are part of the eligible perimeter but, due to data quality issues, the EAD has been calculated in standard method. This justifies that for a counterparty which has expositions calculated in both standard and internal methods, we will have an advanced and standard CVA charge. In the COREP CVA template, we should state the number of counterparties calculated in advanced method (r020) and in standard method (r030), the sum of all counterparties should appear in r010. Related to eba_v0641_m, we remove the duplicates between the 2 calculation methods to fill the r010, in order to avoid the double counting of counterparties for which we have both of STD & ADV CVA. Knowing the fact that we can have the both methods for a given counterparty, should we report strictly the sum of r020 and r030? Or should we continue to consider the r010 as the sum of counterparties that generate KCVA, disregarding the calculation method used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4146
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

COREP template C 05.01-validation rule v0269

Is it correct that the formula in COREP Table C 05.01, r100,c040 does not take into account the new cell r440,c040 (Adjustments due to IFRS 9 transitional arrangements)?

  • 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_4066
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Finrep validation rules of F 02.00 and F 16.01

In report F_16.1 the income is broken down by Derivatives - Trading ; Debt securities; Loans and advances and Other assets. In report F_02 the income is broken down by Accounting portfolio and Other assets so we believe rule v5598_i may not alwasy be true. The same logic is also for liabilities therefore rule v5601_i may not always be true.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4009
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Clarifying the Impact of the new securitisation framework on template C 14.00

The ITS clearly states that securitisation calculated according to the new reporting Framework won't be reported in templates C 12.00 and C 13.00 but only in template C 02 00."Securitisations the risk weighted exposure amount of which is determined based on Regulation (EU) No 575/2013 as amended by Regulation (EU) 2017/2401 (amended CRR), i.e. where the risk-weighted exposure amount is calculated in accordance with the revised securitisation framework, shall not be reported in this template, but only in template C 02.00. Equally, securitisation positions which are subject to a 1250% risk weight in accordance with the amended CRR and which are deducted from CET1 in accordance with Article 36(1) point (k) (ii) of the amended CRR, shall not be reported in this template, but only in template C 01.00"For exposures calculated with this new Framework as report C 12.00 and C 13.00 are not relevant anymore, we were wondering if columns like c170/ c180 of template C 14.00 should always be filled?

  • 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_4005
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

FINREP Validation rule v5116_m

We wonder about the consistency of FINREP Validation rule v5116_m.v5116_m: [F 13.01] sum({F 13.01, r050, (c010-050)}) <= {F 05.01, r120, c060} - Value Inconsistency : F13.01 r050, (c010-050) = Maximum amount of the collateral or guarantee that can be considered for lending for house purchase; F 05.01, r120, c060 = Carrying amount for lending for house purchase - Scope of lending inconsistency : F13.01 r050, (c010-050) = only lending for house purchase with collateral or guarantee; F 05.01, r120, c060 = lending for house purchase with or without collateral or guarantee - Economic agents inconsistency : F13.01 r050, (c010-050) = all agents ; F 05.01, r120, c060 = Households

  • 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_3991
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Presentation of cash flows related to non performing exposures in the template (C 66.01.a)

It is not clear how to interpret the following instruction: “17. Past due items and items for which the institution has a reason to expect non- performance shall not be reported.”

  • 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_3794
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 15/03/2019

Application of the exemption related to a trusted beneficiary

Has the exemption related to a trusted beneficiary to be applied on an account basis or rather to a list of accounts included in an online banking agreement ? Whose list has to be considered in case of a power of attorney where the initiator is not the account owner ? What happens in case of a shared account where each one holds his own trusted beneficiary lists ?

  • 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_4360
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/03/2019

Applicability of SCA to ‘card payments initiated by the payee only’

Are card payments that are initiated by the payee only on the basis of (1) an initial mandate by the payer authorizing the payee to initiate the periodic payments and (2) a pre-existing agreement between the payer and the payee for the provision of products or services, subject to the RTS SCA requirements?

  • 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_4031
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Subsequent instances of a recurring card payment transaction, other than the first, initial one, are transactions initiated by the payee only. This is also the case for card instalment transactions.

Are the subsequent instance of card payment recurring transactions (other than the first, initial one) and of instalment transactions (again, subsequent to the initial one) transactions initiated by the payee only?

  • 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_4404
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Payee-initiated transactions with irregular period or variable amount

Please clarify whether standing agreements between a customer and a merchant resulting in subsequent billing (irregular or otherwise) to be payee-initiated transactions, and as such excluded from the SCA requirement.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4131
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Transactions initiated via Interactive Voice Response (IVR) solutions

Do transactions initiated via Interactive Voice Response (IVR) solutions qualify as telephone orders and are therefore excluded from the scope of the RTS SCA requirements?

  • 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_4058
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019