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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

Original maturity for off balance sheet items

How is the "original maturity" identified for items in CRR Annex 1 (2)(b)(ii)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

’Appropriate prudential requirements’ with regard to ancillary services undertakings for the assessment of the condition in Article 113(6)(a) CRR.

Clarification is sought on the term “appropriate prudential requirements” with regard to ancillary service undertakings for the assessment of Article 113 (6) (a) Regulation (EU) No 575/2013 (CRR).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C 69.00 – Spread calculation

Is the spread calculated from a daily rate or a month-end rate?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

New, Matured, Roll Over classification

How should institutions report the following: Counterparty A has one deposit maturing at the beginning of day 1 for the amount of 200 with an original maturity of 21 days. Counterparty A has booked three replacement trades totalling 225 (100 - 21 days, 50 - 7 days & 75 - 14 days).

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Wholesale Deposits regarding Deposit Insurance Scheme

How can the meaning of “liabilities” in context of Article 28(1) Delegated Regulation (EU) 2015/61 (DR) be interpreted? Does it refer to the total deposit amount from relevant clients which can be multiplied with 20% up to the deposit guarantee scheme limit (d.i.s.l.) and the rest with 40% or shall a deposit with an amount exceeding the d.i.s.l be multiplied as a whole with 40% (i.e. no dividing in 20%- and 40%-Run-Off)?

  • 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

Reporting of QCCP exposures be reported in template C07.00a – validation rule e4895_n

To which exposure class (or sheet) should QCCP exposures which qualify for 2% risk weight under Article 306 of CRR be assigned for the purpose of COREP template C07.00a?

  • 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)

Validation rule v4795_m, C 13.00 - Securitisations

In the case where an institution did not originate any positions in a securitisation what values should be reported in column 010 of template C13.00?

  • 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)

C 09.02 - validation rules v4776_m, v4777_m, v4778_m, v4780_m and v4781_m

According to validation rule v4776_m, the value in row r060 of C 09.02 should be >= the value in row r070 and this for columns (010-070;100-130). We think this rule is only relevant for columns which report amounts and not for columns which report percentages. Hence, we think this rule cannot be applied to column c100 as this column is used to report an average LGD in %. The same remark applies for validation rules v4777_m; v4778_m; v4780_m; v4781_m.

  • 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)

Validation rules v4764_m, v4765_m, v4766_m, v4767_m and v4768_m in template C 08.01

Are validation rules v4764_m - v4768_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)

Clarification of the collateral amounts -validation rules v4759_m & v4774_m

Could you please clarify what amounts need to be reported in columns 150-210 of template C08.01, specifically, for ‘funded credit protection’ ‘real estate’ (column 190), when own estimates of LGD are used.

  • 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)

v4760_m & v4761_m in C 02.00 and C 08.01

Are validation rules v4760_m & v4761_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)

Reporting of credit risk adjustments according to Article 110 of CRR

In relation to SA General credit risk adjustments, as per template C 01.00, row 920, column 010, is an institution also required to report the respective values in column 050 in template C 09.01?Furthermore, should this credit risk adjustment apply for a bank and the bank is not including it in its Tier 2 capital, is the NCA obliged to inform the bank accordingly?

  • 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)

O-SII Buffer on individual and consolidated level

Article 131(5) of the CRD (Directive 2013/36/EU) states that “the competent authority or designated authority may require each O-SII, on a consolidated or sub-consolidated or individual basis, as applicable, to maintain an O-SII buffer..”. May the competent authority or designated authority also require a single O-SII to maintain an O-SII buffer both on a consolidated AND individual basis?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/10 - Guidelines on criteria to identify other systemically important institutions (O-SIIs)

Validation rule v4886_m

A new validation rule v4886_m has been added to taxonomy 2.6 which specifies that : [C 03.00 (r010;030;050;070-120)] {c010} < 1 This rule fails to consider that a firm may hold surplus capital for other purposes (such as Large Exposures) that would cause failure of this rule.

  • 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)

Substitution approach for exposure and guarantor under different approaches

In case a bank has both SA and IRB positions is it possible to apply the substitution approach when the exposure and the guarantor are treated by the institution under different approaches? In this sense, can the substitution approach be applied if the exposure is under the IRB approach and the guarantor under the SA? If so, for the reporting purposes, 1) Can Inflow arise on CR-IRB columns from CR-SA (outflow) columns? 2) How CRMs under IRB approach are reported when related exposure is reported on CR-SA?

  • 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)

Definition of the elements to be included in each type of Assets

We would like more precisions regarding the elements composing the following categories of Assets (template F22.02 of Annex III): - row 010 Asset management - row 060 Custody Assets - row 100 Central Administrative services In other terms, if, for these elements and for instance Collective Investments, we do take into account the amounts of deposits and/or cash, or only the Net (book) value of assets ?

  • 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)

Classification as off-balance sheet items of a committed reverse repo facility or other committed credit facilities where drawing under the facility is conditional upon purchasing or receiving eligible collateral

Would it be possible for an institution to assign a committed reverse repo facility, or other committed credit facility where drawing by the client is conditional to purchasing or receiving eligible collateral by the institution, to one of the risk categories as “other items also carrying [low], [medium/low], [medium] risk and as communicated by EBA”, in accordance with Article 111(1) CRR or Article 166(10) CRR and Annex I?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

General and specific credit risk adjustments

Can a Supervised Entity not recognise changes in impairments, value adjustments or provisions in the calculation of the exposure value and thus avoid the deduction of these amounts from CET1?Or in case a Supervised Entity has changes in impairments, value adjustments or provisions, are these amounts automatically labelled as general or specific credit risk adjustments and shall therefore be accounted for in the calculation of the exposure value of an asset and deducted from CET1? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments

Qualifying own funds included in consolidated own funds

Should an institution which has issued Additional Tier 1 (AT1) and Tier 2 (T2) instruments to external investors, and which is subject to consolidated supervision on the basis of the consolidated situation of its immediate parent financial holding company, apply the restrictions on the consolidated inclusion of AT1/T2 instruments issued by subsidiaries as provided for in Articles 82 and 85-88 of the CRR, where the parent holding company’s only assets are the shares in the institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Annual contributions of institutions – which data should constitute the basis for the calculation of annual contributions to resolution financing arrangements in case of a significant change of the risk profile of an institution

In case of a significant change of the size and risk profile of an institution (in particular as a result of an M&A transaction), which data should constitute the basis for the calculation of the annual contributions to the resolution financing arrangements: (i) data derived from the most recently approved annual financial statements available prior to 31 December of the year preceding the contribution period (i.e. data which effectively precedes the contribution period by two years, e.g. for 2017, the resolution authority would rely on data as of 31 December 2015); or (ii) more recent data that adequately corresponds to the actual size and risk profile of the institution?

  • 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