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Taxonomy 3.0 Validation Rule v3900_s
Our query refers to the EBA v3900_s validation rule of template F 02.00, which despite being non-blocking, we have to justify the module as there are negative amounts. We understand that there may be situations in which the reversal of expenses or income for interests or commissions of the current exercise exceed the expenses or income of the same period. In this situation a negative quantity should be allowed to be reported.
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: 2022_6445 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 10/05/2022 |
Date of rejection: 31/10/2022 |
Date of publication: 31/03/2023
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Treatment of covered deposits when determining the contribution base of Investment Firms
Can the liabilities that arise by virtue of holding clients' money with investment firms, and that are then deposited by investment firms with a credit institution, be considered as deposits that are deducted from the Contribution Base when determining the ex-ante contribution of those investment firms to a resolution financing arrangement?
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: 2017_3579 |
Topic: Resolution financing arrangements |
Date of submission: 01/11/2017 |
Date of rejection: 11/02/2022 |
Date of publication: 18/03/2022
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Contributions to the financing arrangements from ceased banks
Do institutions that cease to exist or to be supervised in a given year prior to the determination or raising of the annual contributions still have to contribute to the financing arrangements?
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: 2016_2872 |
Topic: Resolution financing arrangements |
Date of submission: 16/08/2016 |
Date of rejection: 11/02/2022 |
Date of publication: 18/03/2022
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Definition of "total liabilities"
Does the reference to ‘total liabilities’ in Article 3(11) of Commission Delegated Regulation (EU) 2015/63 mean liabilities and capital, or only liabilities?
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: 2016_2869 |
Topic: Resolution financing arrangements |
Date of submission: 12/08/2016 |
Date of rejection: 11/02/2022 |
Date of publication: 18/03/2022
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Clarification on EBA Final Q&A 2015_2469 / Exemption from bail-in of liabilities to institutions in order to avoid risk of systemic contagion
The answer to Q&A 2015_2469 clarifies that the exception to bail-in in Article 44(2)(e) of Directive 2014/59/EU (BRRD) captures inter-bank unsecured liabilities with an original maturity of less than seven days. Does this exception apply to all inter-institutional unsecured liabilities with an original maturity of less than seven days? In other words, does this exception also capture the liabilities of investment firms that are defined as institutions in Article 2(1)(23) BRRD, alongside the liabilities of other banks or credit institutions?
Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2016_2814 |
Topic: Write-down and conversion of capital instruments |
Date of submission: 04/07/2016 |
Date of rejection: 11/02/2022 |
Date of publication: 18/03/2022
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Reporting of SA exposures in IRB-CIU look-through
Do CIU exposures for which the IRB look-through approach is applied, but which are subject to the Standardised Approach for calculating the risk-weighted exposure amount as per Article 152(4), point (c), of Regulation (EU) No 575/2013, have to be reported in template C 07.00 (CR SA) or in the C 08 templates (CR IRB)?
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: 2022_6528 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 26/07/2022 |
Date of publication: 26/05/2023
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F 46 EBA_v1226
How to match the re-translated opening balance (in current year) with closing balance (from prior year) on F 46 when the constant USD value is being converted to EURO in two different reporting periods with different FX rate? If the same prior year converted value in EURO is stated in opening balance (before restatement row 10), then how and which row does the FX translation impact shall be reflected?
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: 2022_6520 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 19/07/2022 |
Date of publication: 26/05/2023
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Treatment of Security Lending and Borrowing Transactions for LCR purposes
How should Security Lending and Security Borrowing Transactions be reported in the LCR template, considering the changes introduced by the Commission Delegated Regulation (EU) 2022/786 about Security Financing Transactions?
In detail, shall Security Lending and Borrowing transactions be reported as collateral swaps in C 75.00 template or shall they be reported as Security Financing Transactions in C 73.00 and C 74.00?
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_6557 |
Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM) |
Date of submission: 11/08/2022 |
Date of publication: 26/05/2023
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Interest-income on credit impaired financial assets (template F 16)
Template F 16, r0280, of which: interest-income on credit impaired financial assets: if a financial asset was credit impaired during for example Q1, Q2, and Q3, but during Q4 became performing again, should we still report the interest-income reflected on this row in the Q4-reporting?
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: 2022_6350 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 01/02/2022 |
Date of publication: 28/04/2023
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Treatment of TIPS and IP in AE reporting
Should balances kept on accounts related to TIPS (TARGET Instant Payment Settlement) and IP (Instant payments) in the encumbrance reporting, be reported as encumbered or not?
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: 2022_6523 |
Topic: Supervisory reporting - Asset Encumbrance |
Date of submission: 22/07/2022 |
Date of publication: 28/04/2023
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Treatment of additional collateral on top of overcollateralization of Covered bond program
Should a surplus above overcollateralization (above contractual amounts/percentages and also above what rating agencies require to maintain the rating) within a covered bond programme be considered as encumbered, when release and re-assignment of any security requires a signature from external parties (incl. the trustee for the covered bond programme) based on the programme documentation?
If the required signature before withdrawal should still be seen as resulting in encumbrance, also in the case of the situation described below, would it then be relevant, if the Trustee contractually would not be able to say ‘No’ if the after the requested withdrawal the required overcollateralization threshold are still met?
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: 2022_6522 |
Topic: Supervisory reporting - Asset Encumbrance |
Date of submission: 22/07/2022 |
Date of publication: 28/04/2023
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Notional amount reported under SA_CCR model
SA_CCR model: How do we report notional amount in template C 34.02 {r0030, c0030} in Annex I to Regulation (EU) 2021/451 (ITS on supervisory reporting)?
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: 2022_6603 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 07/10/2022 |
Date of publication: 28/04/2023
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K-CON own fund requirements
How should the K-CON requirement be calculated under Article 39 of Regulation (EU) 2019/2033?
Legal act: Regulation (EU) No 2019/2033 (IFR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2022_6473 |
Topic: Concentration risk |
Date of submission: 03/06/2022 |
Date of publication: 28/04/2023
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Applicability of notional and CMV concepts to SFT for the purpose of template C 34.02
For a bank using the FCCM exposure calculation method for SFT according to Chapter 4 of Title II of Part Three CRR (Article 223), it is not clear how to populate columns 0030, 0040/0050 and 0150 of template C 34.02 in Annex I to Regulation (EU) 2021/451 (ITS on Reporting).
The notional amount and the CMV are not recognized concepts for SFT. These parameters are not quoted in any article regarding SFT.
A repo transaction is composed by only 2 parameters, the security posted and the cash received.
In case of a repurchase agreement transaction under the Financial Collateral Comprehensive Method, please precisely answer the following questions:
What is the notional amount of the repo to be reported in column 0030 ?
The security value posted (or the security nominal ?)
The Cash nominal received
The security value posted - the cash received
Not relevant, do not populate
Other, please indicate
What is the current market value of the repo to be reported in column 0040/0050 ?
The security value posted
The Cash nominal received
The security value posted - the cash received
The security value posted as a negative position (column 0050)
Not relevant, do not populate
Other, please indicate
What is the exposure value pre-crm to be reported in column 0150 ?
The security value posted
The security value posted - cash received
Other, please indicate
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: 2022_6630 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 04/11/2022 |
Date of publication: 28/04/2023
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Reporting of central bank exposures - C 40.00
Is the intention of data points {row 0090;col 0010} and {row 0090;col 0020} to exclude central bank claims given individual disclosure in {row 0380;col 0010} under taxonomy 3.0 guidance?
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: 2022_6631 |
Topic: Supervisory reporting - Leverage ratio |
Date of submission: 07/11/2022 |
Date of publication: 28/04/2023
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NACE sector K- 'Financial and insurance activities' in F 06.01
How should the instructions from Regulation (EU) 2021/451, (ITS), Annex V, Part 2, paragraph 92 ‘Institutions shall report loans and advances to non-financial corporations which engage in financial or insurance activities in ‘K – Financial and insurance activities’’ be understood?
As an example, should a counterparty whose primary activity is NACE code 7010 ‘Activities of head offices’ (sector M), who also performs the activity ‘other financial service activities, except insurance and pension funding n.e.c.’ (NACE code 6499) be presented in F 06.01 in sector K ‘Financial and insurance activities’ or in sector M ‘Professional, scientific and technical activities’?
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: 2022_6673 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 28/12/2022 |
Date of publication: 28/04/2023
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NACE reporting in FINREP
In FINREP where presentation towards NACE sector is requested, in case the immediate counterparty is a holding company, should the applicable NACE sector be based on the NACE sector applicable for the holding company itself, or should the NACE sector be based on the NACE sector of the specific obligor under the holding company which receives the funding from the holding company?
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: 2022_6672 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 28/12/2022 |
Date of publication: 28/04/2023
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Finrep validation v11942_m - Collaterals received on NPL
According to the validation rule v11942_m it has been stated that {F 18.00.d, r0070, c0200} + {F 18.00.c, r0070, c0210}
Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
ID: 2023_6711 |
Topic: Supervisory reporting - FINREP (incl. FB&NPE) |
Date of submission: 08/02/2023 |
Date of publication: 28/04/2023
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Whether values to be reported in template C 08.03 and C 34.07 should be based on original obligor or resultant obligor
Should the values reported in template C 08.03 be based on original obligor (immediate counterparty to whom the original exposure amount is assigned) or resultant obligor (counterparty guaranteeing the original exposure and whose PD or LGD is used for RWA calculation as result of PD/LGD substitution approach)?
Consistently, as template C 34.07 has a similar structure as template C 08.03, can the logic applied for reporting values on original/resultant obligor basis in template C 08.03 also be applied to template C 34.07?
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: 2023_6718 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 15/02/2023 |
Date of publication: 28/04/2023
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Definition of domestic for reporting collateral by type
For the purposes of populating the C 34.08 of Annex 1 to the Regulation (EU) 2021/451 it asks for cash to be split by domestic currency and other currencies and sovereign debt to be split into domestic and other. In this context, how should domestic be interpreted? We can think of three possible options:
1) Domestic refers to the country of incorporation of the institution.
2) Domestic refers to the country of incorporation of the client against which the institution has the CCR exposures.
3) Domestic refers to the country of incorporation of the issuer of the debt with respect to the sovereign debt (although this would then seem to conflict with domestic for cash if it is a valid option).
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: 2023_6737 |
Topic: Supervisory reporting - COREP (incl. IP Losses) |
Date of submission: 03/03/2023 |
Date of publication: 28/04/2023
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