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Display of negative interest rate in statement of fees
How should a fee corresponding to negative interest (in case of negative policy interest rate of the respective central bank) be displayed in the Statement of Fees (SoF) pursuant to Article 5 Payment Accounts Directive (PAD) and in accordance with Commission Implementing Regulation (EU) 2018/33 (ITS on SoF)?
Legal act: Directive 2014/92/EU (PAD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/33 - ITS with regard to the standardised presentation format of the statement of fees
ID: 2021_5850 |
Topic: Payment accounts |
Date of submission: 13/05/2021 |
Date of publication: 22/12/2022
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Money broking
What specific services and products are part of money broking?
Legal act: Directive 2013/36/EU (CRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2021_5771 |
Topic: Other issues |
Date of submission: 09/03/2021 |
Date of publication: 22/12/2022
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Qualifying holdings assessment pursuant to the exercise of resolution powers
In the context of the application of resolution tools or the exercise of resolution powers under Directive 2014/59/EU (BRRD), that may imply the creation or increase of qualifying holdings, does the exercise of control by a resolution authority over an institution under resolution or of some or all the rights and powers conferred upon the shareholders of an institution under resolution make the resolution authority subject to the prudential assessment envisaged by Article 22 CRD?
Where the RA of Member State A applies resolution tools or exercises resolution powers in respect of an entity under resolution located in Member State A, which owns qualifying holdings in an entity located in Member State B, is the RA of Member State A subject to the prudential assessment of the competent authority of Member State B in as much as holder of indirect qualifying holding?
Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2021_5765 |
Topic: Interactions with the CRR / CRD IV and the BRRD |
Date of submission: 04/03/2021 |
Date of publication: 22/12/2022
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Interpretation of references to legal acts no longer in force
How should we interpret references to legal acts that are no longer in force?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2021_5698 |
Topic: Other issues |
Date of submission: 25/01/2021 |
Date of publication: 22/12/2022
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Treatment of credit risk exposure for credit institutions accessing the overnight deposit facility via a national central bank
Should a credit institution accessing the overnight deposit facility via a national central bank (NCB) treat its credit exposure as being to the relevant NCB pursuant to Capital Requirements Regulation (CRR) Article 114(4), or to the European Central Bank (ECB) pursuant to CRR Article 114(3)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2022_6467 |
Topic: Credit risk |
Date of submission: 26/05/2022 |
Date of publication: 22/12/2022
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Original maturity of credit lines until further notice
For risk classification as off-balance sheet item according to Annex I CRR, is the original maturity longer than one year where non-retail credit lines until further notice (i.e. no fixed maturity) may be cancelled with 3 months advance notification period and even immediately in case the borrower becoming delinquent or declaring bankruptcy?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2022_6432 |
Topic: Credit risk |
Date of submission: 26/04/2022 |
Date of publication: 22/12/2022
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Definition of 'past due' for the purpose of the LCR
What is the definition of 'past due' for the purpose of calculating liquidity inflows under Article 32(1) of Delegated Regulation (EU) 2015/61 in the LCR? Does the regulation allow for grace periods when determining monies due that are past due?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
ID: 2022_6386 |
Topic: Liquidity risk |
Date of submission: 25/02/2022 |
Date of publication: 22/12/2022
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Distribution of retail and wholesale term deposits in the ASF tables of the NSFR report according to the remaining term of the contract.
What is the term in the ASF tables of the NSFR report for longer than 6 months term deposits which a depositor has the right to terminate earlier and can withdraw these deposits in less than 6 months, when penalties are not applied?
Do the same provisions apply to retail and wholesale deposits?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
ID: 2021_6281 |
Topic: Liquidity risk |
Date of submission: 16/11/2021 |
Date of publication: 22/12/2022
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Residual contractual maturity date applicable to commercial paper issued under a commercial paper program with a firm underwriting commitment to rollover
What should be the residual contractual maturity applicable to commercial paper issued under a commercial paper program with a firm underwriting commitment to rollover?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2021_6087 |
Topic: Liquidity risk |
Date of submission: 13/07/2021 |
Date of publication: 22/12/2022
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Net Stable Funding Ratio (NSFR) calculation by currency for foreign-exchange derivatives contracts
What criteria are to be used to assign as foreign-exchange derivative contract to the respective reporting in a significant / reporting currency in order to apply Article 428d CRR2?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2020_5242 |
Topic: Liquidity risk |
Date of submission: 11/05/2020 |
Date of publication: 22/12/2022
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Excess of collaterals after deduction from netting set for NSFR
What treatment should be applied on excess of collaterals for the NSFR calculation?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2020_5231 |
Topic: Liquidity risk |
Date of submission: 07/05/2020 |
Date of publication: 22/12/2022
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Deduction of software
Should software be deducted from own funds net of the whole amount of tax deductible amortisation that will be recorded throughout their life?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2020_5171 |
Topic: Own funds |
Date of submission: 11/03/2020 |
Date of publication: 22/12/2022
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Maturity reporting for Pillar 3 ESG risks disclosure, Template 1 and 5
How should we treat products without stated maturity (such as on demand, equity, perpetual loans) in the maturity buckets and in the average weighted maturity computation?
E.g. perpetual loans will probably end up in the >20 years bucket, but which year should we use for the computation of the average weighted maturity? Or Equity holdings are mentioned in the instructions, but it's not clear in which maturity bucket we should report them and which year to use for the computation of the average weighted maturity.
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6515 |
Topic: Transparency and Pillar 3 |
Date of submission: 13/07/2022 |
Date of publication: 25/11/2022
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Template 10: other climate change mitigating actions - Columns d and e
Could you specify which kind of answers are expected under 'type of risk mitigated' (column d and e)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6533 |
Topic: Transparency and Pillar 3 |
Date of submission: 28/07/2022 |
Date of publication: 25/11/2022
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Template 5: Banking book - Climate change physical risk: Exposures subject to physical risks
What is the relation between row 1-9 and 10-12? Are rows 10-12 based on the sectors mentioned in 1-9 only, or based on all sectors (including the ones not mentioned in 1-9)?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6541 |
Topic: Transparency and Pillar 3 |
Date of submission: 01/08/2022 |
Date of publication: 25/11/2022
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Clarification on summing columns in Template 10 "Other climate change mitigating actions that are not covered in the EU Taxonomy"
We ask for clarification whether 'columns d' and 'e' in Template 10 (respectively 'Type of risk mitigated (Climate change transition risk) ' and 'Type of risk mitigated (Climate change physical risk) ') should add up to 'column c' ('Gross carrying amount (million EUR) ')?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6564 |
Topic: Transparency and Pillar 3 |
Date of submission: 17/08/2022 |
Date of publication: 25/11/2022
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Template 5 - Definition of time horizons
With regards to the Final draft implementing technical standards (ITS) on prudential disclosures on ESG risks in accordance with Article 449a CRR, specifically regarding Template 5 of related Annex XXXIX, could you specify 'time horizon'?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6537 |
Topic: Transparency and Pillar 3 |
Date of submission: 28/07/2022 |
Date of publication: 25/11/2022
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Template 2 - Row 5 subset
Template 2 of Annex XXXIX to the Final draft implementing technical standards on prudential disclosures on ESG risks in accordance with 449a CRR – Is row 5 a sub-set of rows 2/3/4?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6532 |
Topic: Transparency and Pillar 3 |
Date of submission: 28/07/2022 |
Date of publication: 25/11/2022
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Template 10: Other climate change mitigating actions - Scope of Bonds and Loans
Could you clarify which types of 'bonds and loans' are in scope?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6531 |
Topic: Transparency and Pillar 3 |
Date of submission: 28/07/2022 |
Date of publication: 25/11/2022
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Use of Turnover taxonomy eligibility/alignment or Capex taxonomy eligibility/alignment for Pillar 3 Risks ESG disclosures
Question 1:
We interpret that the wording "general purpose lending part" excludes “specialised lending” and it leaves the door open to derive that Capex may be used for specialised lending and/or when the use of proceeds is known. Could you please indicate if for some of the Pillar 3 reports the Capex taxonomy eligibility/alignment should be used instead of the turnover taxonomy eligibility/alignment. If yes, may you please precise under which conditions Capex taxonomy eligibility/alignment should be used and to which report it applies and potentially to which columns/rows if relevant.
Question 2:
Is there any intentional distinction between the wording “use of proceeds is known” versus the wording “specialised lending”? If yes, could you explain the difference?
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
ID: 2022_6521 |
Topic: Transparency and Pillar 3 |
Date of submission: 21/07/2022 |
Date of publication: 25/11/2022
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