List of Q&As

COREP C17.01 - Consistency of the EBA Taxonomy control v5839_m

Does the Control v5839_m take into consideration the possibility to report a correlated incident?

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 (as amended)

ID: 2020_5434| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 10/08/2020

EBA validation rule v5313_m and v5315_m don`t work in Tax 2.9

EBA validation rule v5313_m and v5315_m don`t work in Tax 2.9

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 (as amended)

ID: 2020_5274| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 22/05/2020

Validation rule (taxonomy 2.6) e4902_n about the risk weighted exposure for Equity in CR SA

Where shall equity exposures treated according to Articles 48(4), 471(2) and 495 (1) CRR be reported in COREP CR SA (C 07.00)?

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 (as amended)

ID: 2017_3414| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 21/07/2017

Treatment of deducted exposures in the calculation of memo items “Risk-weighted exposure amount under SEC-ERBA” and “Risk-weighted exposure amount under SEC-SA” ({C14.01 c447} and {C14.01 c448} respectively)

How to treat deducted exposures in the calculation of the mentioned memo items, to allow for a coherent and homogeneous comparison between the own funds required by the different methods?

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 (as amended)

ID: 2020_5422| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 07/08/2020

Treatment of derivatives not recognized on-balance under national GAAP

In case derivatives are not recognised on the balance sheet according to national GAAP based on BAD, how should they be treated for the purpose of FINREP and asset encumbrance reporting?

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 (as amended)

ID: 2020_5263| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 19/05/2020

Sign convention for “Credit risk adjustments during the current period” {C14.00 c225} and definition of "current period".

The sign convention that should be followed to report credit risk adjustments in column 225 of C14.00 is not clear. In the same way, the “current period” should be further specified.

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 (as amended)

ID: 2020_5421| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 07/08/2020

FORBERANCE CLASSIFICATION

For forborne exposures under probation which, at the time of the initial concession, were performing, if a new measure is granted after 1 year and a half, during which the client has fulfilled points c) and d) of standard 176 when it is still within the probation period, and if the bank, on the basis of its own independent evaluation, does not reclassify the client (see Q&A EBA 2013_618 and 2014_736), is the period of 2 years for exiting the probation period counted again from scratch?Nel caso di una esposizione forbone under probation, che nel momento della prima concessione era performing, se una nuova misura viene concessa dopo 1 anno e mezzo durante il quale il cliente ha rispettato i punti c) e d) dello standard 176, quando è ancora in vigore il periodo probatorio, e se la banca in virtù della propria autonoma valutazione non riclassifica il cliente (vedi Q&A EBA 2013_618 e 2014_736) il conteggio dei 2 anni per l’uscita dal periodo probatorio, riparte da zero?

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_1842| Topic: Supervisory reporting - FINREP (incl. FB&NPE)| Date of submission: 19/02/2015

Sign Convention

Column 030 in C 07.00 (-) VALUE ADJUSTMENTS AND PROVISIONS ASSOCIATED WITH THE ORIGINAL EXPOSURE) has negative sign, while in C 09.01 columns 050to 070 has (+) sign convention. We would like to know that what is the rationale behind having different sign convention for same fact?

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 (as amended)

ID: 2014_1625| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 18/11/2014

Operational Risk - Gross Losses & Rapidly recovered loss events

A credit institution recently changed the scope of the gross losses for operational risk reported in COREP. The credit institution explained that they do not automatically report some types of incidents in the ‘gross losses’ for operational risk in COREP (C17.01a) when the amount is recovered after 5 days. We refer here to transfer of cash involving e.g. a human input error whereby a cash amount is transferred for a far greater size than intended, at the wrong price, or with any number of other input errors, or to the wrong counterparty. The credit institution explained that gross losses for operational risk should be reported in COREP only if there is a P&L movement in the financial statements. Therefore, if the credit institution considers that there is a high probability to recover the amount linked to the operational risk event, even if they recover the money after more than 5 days, they will not increment any amount in the financial statements, they do not consider it as loss, and therefore they will not report the amount in the COREP ‘gross losses’ for operational risk. According to us, the competent authorities, this interpretation seems to be incorrect. Our interpretation is that the gross losses for operational risk in COREP should not be dependent on the decision of the credit institution to book losses in its financial statements for this operational risk event. Therefore, if there is an operational risk event, the amount should be reported in COREP in the ‘gross losses’ for operational risk. The only exception is if the losses are recovered within 5 days, in which case it is considered as a “rapidly recovered loss events” and can be deducted from the reported gross losses in COREp (C17.01a) Could you please clarify which interpretation is correct?

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 (as amended)

ID: 2020_5261| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 15/05/2020

EBA validation rule v7365_m

Is v7365_m stating that for the C14.00 if ({c040} = [eba_RT:x10] or {c040} = [eba_RT:x11]) then {c140} <= {c130} correct?

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 (as amended)

ID: 2020_5402| Topic: Supervisory reporting - COREP (incl. IP Losses)| Date of submission: 04/08/2020

Amended ranking requirement in point (d) of Article 63 of the CRR

Which interpretation of the new requirement in point (d) of Article 63 of Regulation (EU) No 575/2013 (CRR), as amended by Regulation (EU) 2019/876 is correct?Do all banks need to amend the T&Cs of their Tier 2 instruments due to the new wording of point (d) of Article 63 of the CRR in order to be CRR-compliant (considering that there is no respective grandfathering provision in the CRR)? orDo banks for which the resolution authority does not set a subordination requirement with respect to MREL or banks for which the MREL requirement consists solely of the loss absorption amount (as the respective bank is to be wound up under normal insolvency proceedings and not subject to resolution) remain compliant with the new wording in point (d) of Article 63 of the CRR without the need to amend their respective T&Cs?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_4950| Topic: Own funds| Date of submission: 16/10/2019

Grandfathering according to Articles 494a and 494b of the CRR

Should Article 494a(1) and (2) of the CRR also cover points (p), (q), and (r) of Article 52(1) and points (n), (o) and (p) of Article 63, respectively?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_4949| Topic: Own funds| Date of submission: 16/10/2019

Minimum requirement for own funds and eligible liabilities (MREL) - Waivers

Are the conditions of Article 45f(4) (or (3), depending on the case) exhaustive? In other terms, when assessing a request to waive an individual MREL requirement under Article 45f(4) (or (3) depending on the case) of BRRD, is the resolution authority required to assess only the conditions set out in the relevant paragraph (s), or is it allowed to require, in its policies and procedures, the fulfilment of other additional conditions?

Legal act: Directive 2014/59/EU (BRRD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_5009| Topic: MREL| Date of submission: 20/11/2019

Minimum requirement for own funds and eligible liabilities (MREL) - Calibration

When setting a recapitalisation amount enabling the “resolution group resulting from resolution” to meet its prudential requirements “after the implementation of the preferred resolution strategy”, should the resolution authority consider the changes resulting from the whole sequence of actions which implements the preferred resolution strategy, irrespective of the point in time when they are likely to be taken, or only changes resulting from those actions implemented after entry into the formal resolution phase (post-Failing-Or-Likely-To Fail - FOLTF)?

Legal act: Directive 2014/59/EU (BRRD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_4901| Topic: MREL| Date of submission: 06/09/2019

Type of accounts accessible through common and secure communication

Should credit lines (namely “credit cards accounts”), accessible online, be available to Account Information Service Provider (AISP), Payment Initiation Service Provider (PISP) and Card Based Payment Instrument Issuer (CBPII)?

Legal act: Directive 2015/2366/EU (PSD2)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_4856| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 07/08/2019

Payment accounts and reference accounts

Are payment accounts, which are coupled with a reference account, in scope of PSD2 especially Regulation (EU) 2018/389 – RTS on strong customer authentication (SCA) and secure communication (CSC)?

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_4272| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 13/09/2018

Ability of a payment account operated by a payment institution to hold a credit balance in readiness for future payment transactions

Can a payment institution hold clients funds in the related payment accounts for undefined future transactions?

Legal act: Directive 2015/2366/EU (PSD2)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4221| Topic: Other topics| Date of submission: 31/08/2018

Minimum requirement for own funds and eligible liabilities (MREL) – Transitional periods

1) Can resolution authorities set transition periods with an end-date before 1 January 2024?2) Can resolution authorities set a transition period with an end-date before 1 January 2022 (date referred to in the context of the "intermediate target" introduced in the legislation?

Legal act: Directive 2014/59/EU (BRRD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2019_4861| Topic: MREL| Date of submission: 09/08/2019

Credit value date for payment transactions with currency conversion

As a credit entry on an account is possible only in the currency the account is maintained, does this mean that for a payment transaction the credit value date for the payee's account is no later than the business day on which the amount in the payee's account currency is credited to the payee's payment service provider's account?

Legal act: Directive 2015/2366/EU (PSD2)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4150| Topic: Other topics| Date of submission: 20/07/2018

Sanctions list screening in the context of TPPs' services - risk management policy

Is the Account Servicing Payment Service Provider (ASPSP) obliged to recognise if a Third Party Payment Service Providers (TPP) is named on a sanctions list or even take some actions when the TPP becomes a designated entity? How the prohibition of directly or indirectly making funds or economic resources available to designated persons and entities is defined in this context?

Legal act: Directive 2015/2366/EU (PSD2)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2018_4117| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 16/07/2018