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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

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List of Q&A's

Template F 16.01 validation rule v5693_s

Is it possible to report negative income from General Government debt securities in F 16?

  • 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_6825
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 15/03/2024

ALMM - C 70.00 : Report of weekends in template C70

Should entities leave empty weekends and holidays in column ‘Overnight’ even when they have information on current accounts for those days?

  • 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_6824
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 01/11/2023

Transfers to PPE

We have a collateral obtained some years back that was classified as Commercial Immovable property. In the current year the Group decided to transfer this property to PPE and use it for its own branches.  In table 25.1 the below rows exist. Where can we put the transfer (therefore outflow) mentioned above? Outflow for which cash was collected Outflow with replacement by financial instrument Outflow due to negative changes in value

  • 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_6823
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/10/2023

Template C 14.00 column 0287 & Template C 14.01, column 0362

Pursuant to Template C 14.00 (column 0287) and Template C 14.01 (column 0362) of the Regulation (EU) 2021/451 (Version: Reporting Framework 3.2) the synthetic excess spread (SES) should be reported under the section “off-balance sheet items and derivatives”. Does this indicate that all synthetic securitisations have to be reported under “off-balance sheet items and derivatives”? More specifically, does the balance sheet treatment of the securitisation positions in columns 0310 – 0400 refer to the securitisation position itself (i.e. all the columns must be either on-balance or off-balance (e.g. off-balance in case of a CDS)) or to the underlying (i.e. the underlying loans must be reported as on-balance and the synthetic excess spread as off-balance; the result is that in the same row (corresponding to one securitisation position) different columns are reported which can refer to both on- and off-balance positions))? E.g.: An institution acts as originator in a direct synthetic securitisation of loans. There are three tranches (junior, mezzanine, senior) and a synthetic excess spread. Significant risk transfer is achieved. The underlying exposures remain on the balance sheet of the originator.

  • 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_6822
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:

ESG P3 - NACE sector breakdown in Pilar III reporting (templates 1 and 5 and, partially 3)

Should NACE activity codes be consistent between FINREP and Pilar III ESG reporting, or can P3 ESG templates breakdowns be adjusted to differ from FINREP but better align with sustainability linked info?   

  • 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: 2023_6821
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Exemption from strong customer authentication

Do the revisions to Art.10 set out in Commission Delegated Regulation (EU) 2022/2360 of 3 August 2022 amending the regulatory technical standards laid down in Delegated Regulation (EU) 2018/389 as regards the 90-day exemption for account access mean that a payment service user or account information service provider is now limited to accessing only the account balance OR the transaction details for the last 90 days when availing of the revised exemption?

  • 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: 2023_6820
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Aggregation of P&L for Net Interest Income

In Article 22 of draft EBA/RTS/2022/10, it stated to apply 50% to profit when aggregating P&L at currency to get total NII.  If the stress NII at currency level are all profits (as seen in our calculation under +shocks scenario), do I apply 50% to each profit, or profit in one currency should be allowed 100% (if so, should it be the reporting currency, or any chozen currency)? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6819
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as Rejected Q&A: 05/09/2023

Calculation of the NPL ratio for determining F_23.00 to F_26.00 reporting requirements

In calculating the ratio outlined in Article 11(g)(ii) of the ITS on Supervisory Reporting to determine applicability of reporting requirements for F_23.00 to F_26.00, should institutions exclude cash balances at central banks and other demand deposits from both numerator and denominator?

  • 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_6818
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/07/2023

Prudent Valuation: Reporting of AVAs in C 32.03

How should the AVAs of model risk be reported in the template C 32.03. Can the Fair Value Adjustments linked to Model Risk, Model Risk UCS y Model Risk I&FC AVAs be included into the C 32.03?

  • 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_6817
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

Treatment of corporate debt securities issued by entities that are set up to raise financing for the parent company or group in the LCR liquid asset buffer

Can corporate debt securities that are issued by entities that are set up to raise financing for the parent company or group be included in the LCR liquid asset buffer, considering that that the main business of this specific entity within the group is the participation of securities issues, which is one of the activities listed in Annex I to Directive 2013/36/EU?

  • 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: 2023_6816
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Calculation of expected credit losses for guaranteed exposures

We would like to know whether full substitution of the guarantor parameters to the debtor’s parameters (so that ECL are effectively calculated on the guarantor) can take place when calculating ECL on a guaranteed exposure in accordance with Regulation 2016/2067 (IFRS 9) as elaborated on by EBA Guidelines 2017/06.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6815
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

v11962_m;v11963_m; v11964_m; v11965_m; v11966_m; v11967_m; v11968_m; v11969_m; v11970_m; v11971_m; v11972_m; v11973_m; v11974_m; v11975_m; v11976_m; v11977_m; v11978_m; v11979_m; v11980_m; v11981_m; v11982_m; v11983_m; v11984_m; v11985_m; v11986_m; v11987_m; v11988_m; v11989_m; v11990_m; v11991_m; v11992_m; v11993_m; v11994_m; v11995_m; v11996_m; v11997_m; v11998_m; v11999_m; v12000_m; v12001_m; v12002_m; v12003_m; v12004_m; v12005_m; v12006_m; v12007_m; v12008_m; v12009_m; v12010_m; v12011_m; v12012_m; v12013_m; v12014_m;

Why there is still some validation rules which control if Financial Garantee and Collateral are less than the Gross Carrying Amount in FINREP 19.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6814
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/07/2023

EBA VR v7872_m; v7873_m; v7874_m; v7875_m; v7876_m; v7877_m

Why there is still some validation rules which control if Financial Garantee and Collateral are less than the Gross Carrying Amount in FINREP 18.02?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6813
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/07/2023

Impacts on Consolidated Group LCR Deposit Categorisation where a Third Country subsidiary utilises a different threshold

As per Article 3 of the LCR Delegated Act, SME deposits are classified as Retail if their balance is <=€1m threshold. Additionally, Article 25 paragraph 2 defines a €500k threshold criteria for Other Retail Deposits. The national law within the UK has specified these thresholds as £880k and £440k respectively.  We would like to confirm if within the consolidated Group return, the outflow weighting should be applied based on the third country subsidiary regulatory definition or applied based on the LCR Delegated Act definition when converted into the Group’s reporting currency?

  • 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: 2023_6812
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 14/09/2023

Reporting of marginal deposit facility amounts (overnight deposits with the central bank) in template C72.

It is not clear how the amounts in Central Banks regarding the marginal deposit facility should be treated in the calculation of the LCR and reported in C72. In fact, some institutions are reporting it in row 0050 (“Withdrawable central bank reserves”) and other institutions in row 0060 (“Central Bank assets”). Which one is the correct row?

  • 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: 2023_6811
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/04/2024

Template 10

The Annex II of the Commission Implementing Regulation (UE) 2022/2453 states that the Template 10 (“Other climate change mitigating actions that are not covered in Regulation (EU) 2020/852”) shall include “exposures of the institutions that are not taxonomy-aligned as referred to in Regulation (EU) 2020/852 according to templates 7 and 8 but that still support counterparties in the transition and adaptation process for the objectives of climate change mitigation and climate change adaptation. Those mitigating actions and activities shall include bonds and loans issued under standards other than the Union standards”. As a consequence, which of this two following options should institutions follow in order to select the Bonds and the Loans that shall be disclosed in Template 10? The Bonds and the Loans that the institution shall select to be disclose in the Template 10 are only those eligible according to the EU Taxonomy, but that are not taxonomy-aligned (i.e. Bonds and Loans that could not be covered in Template 7 or 8); The Bonds and the Loans that the institution shall select to be disclose in the Template 10 are both those eligible according to the EU Taxonomy, but that are not taxonomy-aligned and those that have been defined environmentally sustainable according to standards other than the European Union ones (i.e. Bonds and Loans that are not eligible).  

  • 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: 2023_6810
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Pillar 3 ESG Template 7 - Trading book

Should the Trading book be considered in the “Other assets excluded from the numerator for GAR calculation (covered in the denominator)”, as positioned under the EU Taxonomy template 1? Or should it be left in the “Other assets excluded from both the numerator and denominator for GAR calculation” category as in Pillar 3 ESG Template 7, leading to an inconsistency of reporting between the two templates?

  • 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: 2023_6809
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Remuneration policy disclosure regarding Management Bodies of subsidiaries of an EU parent institution

We would appreciate the EBA to shed light on the disclosure requirements about remuneration for EU parent institutions for the purpose of the Pillar 3 Disclosure Report and under Annex XXXIV of the Commission Implementing Regulation (EU) 2021/637. Indeed, requirements under the Annex stipulate that information on members of the Management Body disclosed under “Template EU REM1 – Remuneration awarded for the financial year” shall, in accordance with Article 13 CRR, be disclosed on the basis of their consolidated situation. In such case, the disclosure entity will solely reflect, in the columns related to Management Body, information on their own management body while information on the identified staff of the management bodies of subsidiaries shall be disclosed under the relevant business area. We would kindly ask for detailed explanations on how EU parent institutions shall disclose the Management Body members of their subsidiaries in terms of columns within “Template EU REM1 – Remuneration awarded for the financial year” (i.e., under column a/b, c or d) and “Template EU REM5 – Information of staff whose professional activities have a material impact on institutions’ risk profile (identified staff)”.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2023_6808
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2024

Application of the behavioural assumption of a 5-year cap for non-maturity deposits

Regarding paragraph 111 of the Guidelines on Interest Rate Risk in the Banking Book (EBA/GL/2022/14), and in relation to Article 98(5a) of the CRD, could you please confirm that the behavioural assumption of a 5-year cap on the average repricing of non-maturing deposits should not be understood as a modelling requirement neither for the Supervisory Outlier Tests (SOT) nor for the ongoing management of interest rate risk but as an alternative and additional measure of interest rate risk that complements the existing IRBB management framework?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities
  • ID: 2023_6807
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as final Q&A: 03/11/2023

Possibility of treating the amounts deposited on the ECB “Marginal Deposit Facility” as liquidity inflow for determination of the Liquidity Coverage Requirement

Confirmation is requested on the possibility of treating the amounts deposited on the ECB  “Marginal Deposit Facility” as liquidity inflow for determination of the Liquidity Coverage Requirement (LCR ratio), based on the provisions of article 32 of Commission Delegated Regulation (EU) 2015/61

  • 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: 2023_6806
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 14/09/2023