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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

Reportable maturity for ALMM C69 PRICES FOR VARIOUS LENGTHS OF FUNDING

In what time bucket in template 69 shall deposits without stated maturity be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_2051
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

How the various types of sight deposit are to be treated in ALMM templates C68.00, C69.00 & C70.00, and whether it is possible to achieve a consistent treatment given the differences in requirements across these templates.

How are the three types of sight deposit (current accounts, instant access savings and term-less cash ISAs) to be treated in templates C68.00, C69.00 & C70.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1901
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

C69.00 – Time-periods covered by column set

What are the intended time periods for the columns “Spread” and “Volume” in template C69.00 – Prices for Various Lengths of Funding?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1802
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Possible redundant “overnight” in text.

Possible redundant “overnight” in text causing confusion.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1735
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Template C 69.00: Clarification needed about definition of transaction volume and maturity

What is meant by transaction volume in template C 69.00 and which maturity should be reported (initial or residual maturity)?

  • 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_1700
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Calculating the threshold of 1% of total liabilities

When completing template C67.00 and C68.00 items exceeding a threshold of 1% of total liabilities are to be reported. For a report in a significant currency, is the threshold of 1% versus total liabilities in all currencies or versus total liabilities in the significant currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1952
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Concentration of funding by counterparties - maturities and product types for fair value of derivaties and collaterals

Institutions shall report the total of all other remaining liabilities in section 2; shall we also report weighted average initial maturity and weighted average residual maturity for the remaining liabilities or the average maturities should only be reported for counterparties exceeding a threshold of 1% of total liabilities ? How should we treat received collaterals and the fair value of derivatives, as they don’t fit in any category of product type provided in Annex XXI - Instructions for completing the additional monitoring tools template(UWF, UWNF, REPO, CB, ABS, IGCP) ? And what maturity should we assume for this kind of liabilities ( 1 day, or the initial/ residual maturity of a derivative)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1829
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Principles for completing template C67.00

Should we include items with no maturity and on-demand deposit in template C67.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_1731
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Eligibility of religious communities or churches

Are churches or religious communities eligible protection providers under all approaches and thus included in the list of providers of Article 201 with reference to paragraph 1(b)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1908
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/12/2015

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

Application of the top-down approach based on EL calibration (article 160 al.2) - purchased receivables

Do these methods apply for other non-retail purchased receivables (i.e. institutions and sovereigns) ? For example, can an institution PD’s be calibrated using these top down approach based on EL calibration ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2023
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 27/11/2015

Definition of disputed margin call under Article 285(4)

What is the relevant definition of margin call dispute for the purpose of doubling the margin period of risk, under Article 285(4), for netting sets which have experienced a material number of extended disputes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1986
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/11/2015

CVA Risk Charge Calculation for derivatives in the banking book with local GAAP

Do institutions that use local GAAP for accounting purposes and do not mark-to-market derivatives in the banking book have to calculate a CVA Risk Charge for derivatives in the banking book?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1975
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/11/2015

Treatment of equity, equity index and commodity futures/forward contracts under Part three, Title IV of Regulation (EU) No 575/2013 (CRR)

Shall equity, equity index and commodity futures/forward contracts be treated as exposure in an underlying instrument or should they be treated as combination of long and short position (holding of the underlying and borrowing maturing on the delivery date of the futures/forward contract)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1812
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/11/2015

Directorships

What is the correct interpretation of Article 91 (4) b) ii) of CRD IV setting the rules for quantifying executive and non-executive directorships within undertakings in which the significant institution holds a qualifying holding? i. An individual holding directorships in four undertakings in which the significant institution holds a qualifying holding will be treated as one single directorship with the directorship held within the significant institution being treated as a separate directorship. ii. An individual holding directorships in four undertakings in which the significant institution holds a qualifying holding with the directorship held within the significant institution not being treated as a separate directorship.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1595
  • Topic: Internal governance
  • Date of submission:
  • Published as final Q&A: 13/11/2015

Credit risk - standardised approach

Can cash equivalents be assigned a Risk weight of 0%? What is the definition of an equivalent cash item?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2001
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 13/11/2015

Own funds – Share premium accounts

There is an agreement for transfer of profit and coverage of losses (i.e. Profit and Loss Transfer Agreement, PLTA)  between the credit institution in question and its mother credit institution, therefore the shares of the credit institution are in the future no longer eligible as a CET1 items (confer Question ID 408/2013 – now archived). In conjunction with the out-phasing of these shares pursuant to the transitional provisions in Article 484 ff CRR, the questions arises if the share premium accounts also have to be out-phased or if they are still eligible as CET 1 instruments according to the provisions laid down in Article 485 para. 2 CRR.Are the conditions set out in Article 28 para. 1 letter (i) CRR met, if a credit institution has also (in addition to CET 1 instruments) T2 instruments which may be repaid before liquidation only with a proportional deduction of the net losses incurred during its lifetime?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1895
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/11/2015

Specific credit risk adjustments

Which item in the CA1 report should be used for reporting "immediate reduction in Common Equity Tier 1 capital" as described under Article 1 paragraph 1 second subparagraph of the Commission Delegated Regulation (EU) No 183/2014, in order to reduce the amount of exposure for specific credit risk adjustments for the purposes of calculation of risk-weighted assets?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2014_1087
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/11/2015

Intragroup liabilities elimination with joint venture company

CSOB owns 55% in the joint venture company. In the paragraph 9 is written that "For the purpose of calculating the basic annual contribution of a group entity, the total liabilities to be considered should not include the liabilities arisen from any contract which that group entity concluded with any other entity which is part of the same group. However, such exclusion should only be possible where each group entity is established in the Union, is included in the same consolidation on a full basis, is subject to an appropriate centralized risk evaluation, measurement and control procedures, and if there are no current or foreseen material practical or legal impediments to the prompt repayment of the relevant liabilities when due. This should prevent liabilities from being excluded from the basis of calculation of the contributions if there are no guarantees that intragroup lending exposures would be covered where the financial health of the group deteriorates. " CSOB for the joint venture company uses proportional method of consolidation, also eliminating the 55% of intragroup liabilities for the regulatory purposes and prudential reporting. The question is if for the basic resolution contribution puproses also elimitate the 55% of those intragoup liabilies or not (not full method of consolidation applied).

  • 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: 2015_2029
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 30/10/2015

Exclusion of Intragroup Liabilities -Treatment of intra-group derivative contracts

How to apply requirement of Article 5 (4) to substitute any accounting value of liabilities arising from derivative contracts by a corresponding value determined in line with Article 5 (3) and possibility to exclude specific intra-group liabilities according to Article 5 (1) a)?

  • 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: 2015_1924
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 30/10/2015