List of Q&As

Validation Rules

There are several validations that do not appear to be appropriate. 1. v1231_m and v1318_m These validations require the prior period closing balance to equal the current period opening balance. However, given there is a separate column for profit/loss attributable to the parent on table 46 (column 100), the opening balance will not equal the closing balance. 2. v2668_s This validation requires Table 46 rows 010-040,110,190,210, columns 90 and 110 to be

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: 2013_663 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 16/12/2013 | Date of publication: 22/08/2014

Recognition of Cashflows for NSFR reporting

In case of partial payments on assets/liabilities, should each partial payment be reflected in the corresponding time bucket, or in total on the contractual maturity? Does this apply only to capital cashflows or also to interest rate cash flows?

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: 2013_656 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 16/12/2013 | Date of publication: 22/08/2014

Capital eligibility in relation to intragroup guarantees - interpretation of "seniority"

How should we interpret "seniority" as used in Article 28(1)(l) of Regulation (EU) No 575/2013 (CRR) (and likewise in Articles 56(e) and 63(e))?

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

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

ID: 2014_903 | Topic: Own funds | Date of submission: 05/03/2014 | Date of publication: 22/08/2014

Definition of Accumulated Writte-Offs to be reported in column 110 of Table 7

The ITS 2.49 defines accumulated write-offs as follows: The column “Accumulated write-offs” includes the cumulative amount of principal and past due interest of any debt instrument that the institution is no longer recognizing because they are considered uncollectible, independently of the portfolio in which they were included. These amounts shall be reported until the total extinguishment of all the institution’s rights (by expiry of the statute-of–limitations period, forgiveness or other causes) or until recovery. Does this amount refer to the write-offs from the initiation of the exposure, or only cumulatively, as it relates to the current reporting period (please specify if year or quarter)?

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: 2013_643 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 12/12/2013 | Date of publication: 22/08/2014

Underwriting Commitments

Can underwriting commitments as described under Article 345 of the CRR be included in the Exposure measure of the Leverage ratio?

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

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

ID: 2014_839 | Topic: Leverage ratio | Date of submission: 11/02/2014 | Date of publication: 22/08/2014

Large exposures - major trading currencies in overnight transactions

How are the major trading currencies to be determined under Article 400(2)(f) of the CRR? Clarification is needed on what is to be considered a major trading currency under Article 400(2)(f).

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

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

ID: 2014_837 | Topic: Large exposures | Date of submission: 11/02/2014 | Date of publication: 22/08/2014

Assessment criteria of the conditions of forbone exposures that are performing

Performing exposures with forbearance measures are distinguished into these that were considered as performing from the date when forbearance measures were extended (see paragraph 178) and these that were previously non-performing and have been reclassified from the non-performing category. Is there a distinction regarding the assessment criteria for these two types of exposures or have all performing exposures with forbearance measures to be assessed on a quarterly basis (see paragraph 177), although the class of formerly non-performing exposures is exposed to a higher risk to become non-performing again as compared to these that have always been performing since forbearance measures were extended?

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

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

ID: 2013_618 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 03/12/2013 | Date of publication: 22/08/2014

Holding in an undertaking that is neither a financial sector entity nor outside the financial sector

According to Article 89 (1) of the CRR, a holding in an undertaking that is not a financial sector entity, carrying on certain ancillary activities (for which guidelines are pending to be issued by the EBA), shall not be treated as a qualifying holding outside the financial sector. In addition, the aforementioned holding does not seem to be captured neither by the deductions from eligible capital items (Articles 36, 56, 66) since relevant deductions relate only to holdings in financial sector entities. Therefore, shall a holding in an undertaking that is not a financial sector entity, carrying on certain ancillary activities, be treated as a holding in a financial sector entity or as an exposure which should be risk weighted?

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

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

ID: 2013_630 | Topic: Own funds | Date of submission: 10/12/2013 | Date of publication: 22/08/2014

LR: Amout due for secured lending transaction

Hi For secured lending transaction, Amount due corresponds to the amount of outflows : does it mean after the application of the rate defined in article 422.2 of the regulation, or before application of this rate? Same question regarding tab 53 and inflows (cell c 010, 030, 050) Regarding tab 53, Row 990 (total cash inflows excluded due to the cap), does this value have to be computed by the report or will be filled with an automatic formula based on the different cells ? Where could we find this formula ? Thanks for your answer Regards

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: 2013_557 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 25/11/2013 | Date of publication: 22/08/2014

Validations

Can the EBA review the attached file which includes specific validations which we believe may be illogical or contain errors. Where appropriate can the EBA amend both Annex XV and the taxonomy.

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: 2013_524 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 12/11/2013 | Date of publication: 22/08/2014

Alternative treatment of the exposure measure: Notional amount

How do we have to report the notional of derivatives, do we have to sum up all derivatives in absolute value?

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: 2013_396 | Topic: Supervisory reporting - Leverage ratio | Date of submission: 16/10/2013 | Date of publication: 22/08/2014

C 51.00 Liquid assets - reporting of intransferable liquidity surpluses

How should surpluses of liquidity held by local legal entities be reported, if these can not be freely transferred to the consolidated entity in times of stress?

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: 2013_386 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 15/10/2013 | Date of publication: 22/08/2014

Reporting of collateral swaps

We do not understand how collateral swaps should be integrated in the reporting template. o Indeed, to calculate the inflows / outflows concerning reverse repos and repos, there should theoretically be a cap on the difference between the cash value of the operation and the market value of underlying security. To calculate the inflows / outflows generated by collateral swaps, the same kind of calculation should be done, but without the cap. o Since operationally the same cells should be used to integrate repos / reverse repos and collateral swaps in the EBA template, we do not understand how this can give adequate results in terms of LCR ratio calculation.

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: 2013_303 | Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) | Date of submission: 30/09/2013 | Date of publication: 22/08/2014

Items associated with particular high risk secured with eligible real estate

How do we treat the exposures that would have been otherwise categorised as "Items associated with particular high risk" and which at the same time are secures with mortgages on immovable property? a) Ignore the collateral which opposes the spirit of Regulation (EU) No 575/2013 (CRR) and Credit risk mitigation (CRM) i.e. CRM is recognised when it decreases the Credit risk? b) Recognise them in the exposure class "Secured with mortgages on immovable property"? Additionally, if these items are also in default, should they be recognised in the "In default" exposure class? c) Recognise them in the exposure class "Items associated with particular high risk" and apply the lower RW that are associated with the exposures secures with mortgages on immovable property?

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

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

ID: 2013_215 | Topic: Credit risk | Date of submission: 06/09/2013 | Date of publication: 14/08/2014

Groups including an investment firm referred to in Article 95(1) of the CRR controlled by a financial holding company or mixed financial holding company

How shall the own funds requirements be calculated for a group including an investment firm referred to in Article 95(1) controlled by a financial holding company or mixed financial holding company (and no credit institutions)?

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

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

ID: 2014_1105 | Topic: Own funds | Date of submission: 24/04/2014 | Date of publication: 01/08/2014

Clarification regarding the legal opinion mentioned in Article 305 of Regulation (EU) No 575/2013 (CRR)

Is it correct to assume that the specific legal opinion mentioned as a prerequisite in Article 305(2)(c) CRR only needs to confirm that the other prerequisites 'individual client segregation' in Art 305(2)a) and the facilitation of the portability of client assets under Art 305(2)(b) are in place and fulfilled (in a sense that the respective legal position of the client is enforceable under respective law(s)), or does the legal opinion need to address additional legal questions beyond that scope? In the latter case what kind of legal questions beyond Art 305(2)(a) and (b) would such legal opinion need to address?

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

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

ID: 2014_1102 | Topic: Market risk | Date of submission: 23/04/2014 | Date of publication: 01/08/2014

Inflows - Monies due from non-financial customers

What should be considered as “contractual commitment to extend funding”, is it entire granted off-balance commitment for particular client (e.g. credit card limits) or amount which is contractually going to be transferred to this client over 30 day horizon? Should the cap be calculated on the net basis for all clients on the client-by-client basis?

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

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

ID: 2014_897 | Topic: Liquidity risk | Date of submission: 05/03/2014 | Date of publication: 01/08/2014

Accounting Scope of Consolidation

Do you agree that the term “within the accounting scope of consolidation” refers to the debtor’s accounting scope of consolidation? Do you agree that the group of connected clients according to large exposure methodology is an adequate approach?

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_1012 | Topic: Supervisory reporting - Other | Date of submission: 26/03/2014 | Date of publication: 25/07/2014

Operational risk - compliance risk

Does the definition of operational risk include compliance risk?

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

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

ID: 2014_1153 | Topic: Operational risk | Date of submission: 07/05/2014 | Date of publication: 25/07/2014

Supervisory powers Liquidity

Does Article 412(5) of Regulation (EU) No. 575/2013 (CRR) prohibit the competent authorities from imposing a “Liquidity-Add-on” (e.g. LCR-requirement above 100%; similarly to a Capital-Add-on according to Article 104(2) of Directive 2013/36/EU (CRD) according to Article 104(1)(k) and/or Article 105?

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

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

ID: 2014_1077 | Topic: Liquidity risk | Date of submission: 15/04/2014 | Date of publication: 25/07/2014