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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

Inconsistency in validation rule v5016_s for C 05.01

Is validation rule v5016_s consistent for rows 130 and 136 of the C 05.01?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3516
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Cap on the own funds requirement for a net position

Article 335 refers ‘The institution may cap the own funds requirement for specific risk of a net position in a debt instrument at the maximum possible default-risk related loss.....’. This article suggests that the Specific Risk requirement in column 060, rows 260 to 320 (column 060) of template C 18.00 should be the adjusted ‘capped own funds requirement’ and reduced to the maximum loss.However, the validation rules v0578_m and v0579_m require that column 060, rows 310 and 320 are the result of column 050 multiplied by 0.08 or 0.12. Of course, capping and adjusting the specific risk breaks these rules and prevents submission. Should the requirement itself be reduced or should the Net position in column 050 of the relevant rows be adjusted?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3513
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/12/2017

Nominal value of collateral received - not available for encumbrance

Point 16 of Annex XVII on Asset Encumbrance reporting states that "Assets are non-available for encumbrance" when they have been received as collateral and the reporting institution is not permitted to sell or re-pledge the collateral, except in the case of a default by the owner of the collateral. We understand from the above that 1. we should only report in Column 070 of AE-COL template, the collateral received from our clients up to the amounts of their actual exposure on the reporting day. 2. Question arise on the rule to follow to report the collateral per issuers type/type of securities in column 70. Example: At reporting date: Client 1 has €1,000 cash and €2,000 securities (€500 Govies, €1000 Financial Corps, €500 Non Financial Corps) in its account with our company. Both the cash and securities accounts of client 1 are flagged as pledged in favour of our company in case of client1's default. Client 1 has entered into deals exposing our Company to €1,200 (Exposure in Basel III) In the books (off balance sheet) of the company, the collateral received will amounts to €3,000 In AE report AE COL column 70, base on point 16 of Annex XVII of ITS, we understand that we should not report €3,000 since our company could only sell the collateral up to the level of Client 1 exposure, ie €1,200 + relevant margins. If this this understanding is correct and €1,200 + relevant margins should be reported, question arises on the way we should select this amount amongst the total collateral received. The implemented selection will indeed impact the content of the reporting rows 150 to 230. We could indeed pick up €500 Govies, €500 Non Financial Corps and €200 cash or €1,000 Financial Corps and €200 Non Financial Corps), any other configuration

  • 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 (repealed)
  • ID: 2017_3512
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Scope of the Covered Bond Exemption as set out in Article 30 of the Margin Rules.

Does the exemption in Article 30 of the Margin Rules concerning OTC derivatives concluded in connection with covered bonds apply where the conditions in Article 30.2 are satisfied in respect of all such covered bonds or only to those covered bonds that are issued by credit institutions that have their registered office in the European Union and which are subject to special public supervision designed to protect bond holders?

  • Legal act: Regulation (EU) No 648/2012 (EMIR) - only RTS 2016/2251
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2251 - RTS on risk mitigation techniques for OTC derivatives not cleared by a central counterparty (CCP)
  • ID: 2017_3511
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Treatment of expected loss amounts in validation rule v4772_m

Is validation rules v4772_m 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 (repealed)
  • ID: 2017_3509
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/12/2017

Reporting of transfer between capital surplus (share premium) and retained earnings in FINREP F 46 template.

Under the Hungarian legislation negative balance of retained earnings could be offset by a transfer from other elements of own funds. If such transaction occurs how should it be reported in template F46?

  • 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 (repealed)
  • ID: 2017_3504
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Incorrect validation rule - deposits guarantee scheme

We think that the validation rule v4134_m is incorrect.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2017_3502
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 04/12/2020

FINREP Template F20.04 (r210,r230)

Template F 20.04, row 210 reports ”Non-financial corporations – Of which: Loans collateralized by commercial immovable property”. However, in Hong Kong there could be non-financial corporations (NFC) borrowing loans that are collateralized solely by ”Residential immovable property” rather than by “Commercial immovable property”. For this case, should the corresponding loan amount be reported in row 230? Similarly, should household (HH) borrowing loans that are collateralized solely by ”Commercial immovable property” require to be reported in row 230, “Households – Of which: Loans collateralized by residential immovable property”?

  • 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 (repealed)
  • ID: 2017_3486
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Question refer to Guidelines on disclosures requirments under Part Eight of Regulation No 575/2013 template 11 EU CR1-A Credit quality of exposures by exposure class and instrument

How to report data in Pillar 3 template 11: EU CR1-A Credit quality of exposures by exposure class and instrument?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2017_3481
  • Topic: Transparency and Pillar 3
  • Date of submission:

International Organisations allocated to the 'Institutions' exposure class

Could you please advise based on which criteria are International Organizations allocated to the “Institutions” exposure class under IRB 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: 2017_3479
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Reporting of revocable off-balance sheet commitments in FINREP IFRS9 template F 9.1.1

Where should the revocable off-balance sheet commitments be reported in FINREP IFRS9 template F 9.1.1? Annex V, Part 2, paragraph 103 requires that information on loan commitments, financial guarantees and other commitments given and received shall include both revocable and irrevocable commitments. Template F 9.1.1 includes three main categories: "off-balance sheet commitments and financial guarantees under IFRS 9 impairment”; “Other commitments measured under IAS 37 and financial guarantees measured under IFRS 4” and “Commitments and financial guarantees measured at fair value”. A revocable off-balance sheet commitment is not in scope of IFRS 9 Impairment, IFRS4, IAS37 (there is no contractual obligation which is a condition for IAS37) nor is it measured at fair value. Where should such a revocable off-balance sheet commitment be reported in template F 9.1.1? Does it have to be reported in F 9.1.1?

  • 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 (repealed)
  • ID: 2017_3478
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of securitisation instruments in FINREP templates F 04.01 – F 04.04

How should Residential Mortgage-Backed Security (RMBS) instruments be reported in FINREP templates F 04.01 – F 04.04? Which counterparty sector should the RMBS be assigned to?

  • 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 (repealed)
  • ID: 2017_3477
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Definition of "hybrid contracts" in FINREP template F 08.01

What shall be considered a ‘hybrid contract’ for the purposes of reporting FINREP template F 08.01?

  • 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 (repealed)
  • ID: 2017_3476
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Where to include nostro current account balances that Bank of Cyprus maintains with other credit institutions in LCR-Inflows (Template 74)

Where should we include nostro current account balances that Bank of Cyprus maintains with other credit institutions in Template 74 of LCR: in line 1.1.2.2.2 monies due from financial customers or 1.1.6 monies due from assets with an undefined contractual date?

  • 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: 2017_3475
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP F 12.1 Movements in allowances and provisions for credit losses

How shall the impact of transfers between impairment stages be reported in template F 12.1.?

  • 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 (repealed)
  • ID: 2017_3474
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule e4901_n

Validation rule e4901_n (active as from DPM 2.6.0) states the following: [C 07.00.a (r140-170;190;210;220;250-280, c010-040;150-240, s014)] {C 07.00.a} = empty.We have values reported in C 07.00, s014, r140 relating to unsettled securities trades for which the contractual settlement date has not yet passed. As far as we are aware these trades do not attract a capital charge and we are reporting in on this line so as to show the exposure. Should these fields be left empty?

  • 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 (repealed)
  • ID: 2017_3466
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Promise to pay and financial difficulties

If a customer misses a payment he or she can promise to pay the amount due in the same month (after we have contacted our customer). Should we define such a situation as a promise to pay or as a payment reminder? We have currently defined this situation as a promise to pay (‘Toezegging’ in Dutch), but that may diverge from the EBA perception of the associated risk with a promise to pay. As there have been several discussions on this topic with our supervisor we would appreciate EBA guidance. This should provide us with sufficient information to define this event in such a way that there can be no misinterpretations about meeting forbearance criteria.

  • 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 (repealed)
  • ID: 2017_3463
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Validointissääntö e4900_n, C 07.00 Standardimenetelmän mukaiset pääomavaatimukset (Validation rule e4900_n: C 07.00 Capital requirements according to the standard method)

Original questionMillä lomakkeen C 07.00 rivillä ryhmän sisäiset katetut joukkovelkakirjat pitää ilmoittaa? English translationOn which row of form C 07.00 should intra-group covered bonds be indicated?

  • 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 (repealed)
  • ID: 2017_3456
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 22/12/2017

Template C 17.00 (OPR Details) - Reporting on loss adjustments

How should we interpret and treat the negative loss adjustment within the total loss amount?How should we treat the total loss amounts compared to the top loss events and the max single loss?

  • 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 (repealed)
  • ID: 2017_3455
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/12/2017