EBA E-mail alert April 11, 2025

How should an institution calculate gross loss based on the regulatory changes stipulated in Article 318. of the Regulation amending Regulation 575/2013 in the following examples?

Case 1 – Delayed tax payment, penalty interest payment, and system repairment expenses

Case 2 – Delayed tax payment, no penalty interest payment, system repairment expenses. 

Case 3 – Tax to be paid for this year and previous years, no penalty interest, or fine, financial reports for previous year to be revised and re-published. 

Case 4 – Tax to be paid for this year and previous years, no penalty interest or fine, no changes to financial reports for previous year. 

Case 5 – Tax to be paid for this year and previous years, penalty interest and fine, financial reports for previous year to be revised and re-published

Case 6 – Tax to be paid for this year and previous years, penalty interest and fine, no changes to financial reports for previous year 

In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  should the denominator used in the calculation of the percentage be:

1. the gross carrying amount of exposures which GHG emissions are available or estimated  OR
2. the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).

i)When calculating the entity level positions and own funds requirements under Article 325b(4), are intragroup transactions allowed to be included ?

ii)Same question for Article 352(2) determination of consolidated structural position

Which risk-free interest rate curves per currency should be considered as different curves? 

Should the tranche maturity (MT) of less than one year of gross JTD amounts of securitisation tranches resulting from either formula in Art. 257(1) CRR be floored at one year as required by para. 2 of this Article, or can the MT be used without this floor of one year in order to enable scaling, with a floor of three months, as prescribed by Art. 325z(5) CRR in conjunction with Art. 325x(3) CRR? 

On FINREP reports, each counterparty is classified into a counterparty type, like Household or Government. Some government services are provided by volunteers, which raises the question how this should be classified, since the people are technically not employed by the government. Examples include volunteer police or volunteer firefighters and their unions, whose members provide and/or facilitate services specific to governments.