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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.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

Calculation of distributable items for Additional Tier 1 instruments which is inconsistent across the EU

Art. 52 (1)(l)(i) Regulation (EU) No 575/2013 (CRR) refers to ‘distributable items’ as defined in Art. 4 (128) CRR which refers further into applicable national law and the statutes of the institution. Does such reference also consider items that are non-distributable under applicable national law or the statutes of the institution only for common stock or, alternatively, only following a net assets or insolvency related test?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2987
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Prudential treatment of extraordinary ex-post contributions to resolution funds pursuant to Article 104 of the BRRD

Can the extraordinary ex-post contributions to resolution funds provided for by Article 104 of the BRRD be considered as any of the off-balance sheet items mentioned in Annex I of the CRR ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2985
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Pillar 3 Disclosure Requirements for Standalone Solo Banks with a Third Country Parent

Can a solo subsidiary bank located in member states which have a parent located in a third country avail of the CRR exemption set out in Article 13(3) of Regulation (EU) No 575/2013 (CRR) not to apply (in full or in part) the pillar 3 disclosure requirements set out in Part 8 to the extent that they are included within equivalent disclosures provided on a consolidated basis by a parent undertaking established in a third country?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2984
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of "managerial (internal business) purposes" in terms of re-developed IRB model application.

Is there a definition of “internal business purposes” and a list of activities which are considered eligible for internal business purposes in Annex I, Part II, Section 2, paragraph 6 of Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)? Are there any impediments to the usage of re-developed IRB models for managerial/internal business purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2016_2983
  • Topic: Model validation
  • Date of submission:
  • Published as final Q&A: 12/05/2017

Reporting of deductions of receivables assets for cash variation margin provided in derivatives transactions in LR4 (C43.00)

In which row(s) shall the receivables for cash variation margin provided in derivatives transactions be reported?

  • 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: 2016_2982
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting template C40.00 (LR1): Validation rules v0101_h and v0102_h should be amended

Should column 070 of C40.00 be exempted from the application of validation rule v0101_h and v0102_h?

  • 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: 2016_2981
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Application of the risk indicators in specific cases - Liquidity sub-group

How to apply waivers granted by NCA in accordance articles 8 and 21 of CRR (liqiudity requirements / liquidity sub-group) with regard to NSFR when calculating ex ante contributions to resolution financing arrangements for particular firms?

  • 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_2975
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reported currency by issuer/counterparty on a total level (in the Total sheet)

How should assets that are issued or liquidity lines that are granted by a single issuer / counterparty be reported in the Total sheet, provided that the asset received or undrawn committed liquidity lines granted to the institution are denominated in more than one currency? Should the issuer / counterparty be reported on separate lines for separate currencies, or should the currency in which the largest proportion of assets / liquidity was obtained be reported for the aggregated currencies? 

  • 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: 2016_2974
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Asset encumbrance template F32.04 Sources of Encumbrance – Reporting, on individual basis and consolidated basis, of “Source of encumbrance” for securitisations.

What should be reported, on an individual basis and on a consolidated basis, as source of encumbrance in case of securitisations in which the securitised assets remain in the balance sheet (i.e, they have not been derecognised)? “Debts securities issued, of which: asset back securities” or “Collateralised deposits other than repurchase agreements”?

  • 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: 2016_2972
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Treatment of an institution’s guarantees for investments into CIUs

In case of an institution’s guaranteeing the amount of a customer’s original investment into a CIU and a minimum yield:1. To which risk category for off-balance sheet items in Annex I CRR shall these guarantees be assigned, in particular shall this assignment depend on any risk mitigation techniques used by the CIU?2. Shall these guarantees be treated as an exposure in the form of units or shares in a CIU, which would in particular allow the institution to look-through to the underlying exposures of the CIU, provided the conditions for looking-through are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2971
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/10/2017

F 05.00, row 010, column 030 - On demand [call] and short notice [current account] for Central Banks

For template F 05.00 relating to the breakdown of loans and advances by product, Annex V, Part 2.41 states that: ‘balances receivable on demand classified as ‘Cash and cash balances at central banks’ shall also be reported in this template ‘. Besides the cash and cash balances there are also compulsory reserves that have to be reported in this template. In which row do they have to be reported?

  • 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: 2016_2970
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 28/07/2017

Interpretation of Article 88(1) and 89(1) BRRD with respect to the scope of resolution colleges for third country institutions or third country parent undertakings

Is an Article 88 resolution college required for a subsidiary of a third country parent undertaking where that subsidiary itself has subsidiaries in other Member States? If so, is an Article 89 European resolution college also required? In particular, where there is an unrelated sister subsidiary of the third country parent undertaking in another Member State, will both an Article 89 BRRD European resolution college (covering the entire presence of the third country parent undertaking in the Union) and an Article 88 BRRD resolution college (covering any subsidiary which itself has subsidiaries in other Member States) need to be established?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2969
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 10/02/2017

Implementation of default definition - retail portfolio

In the case of retail exposures, can the default definition be implemented in a way that the default of an exposure secured by mortgage extends to unsecured facilities, but not the other way round?Alternatively, should a bank implement the default definition within the retail non SME portfolio consistently at the level of facility, i.e. at the level of product type without extending the default to other facilities?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2968
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/05/2017

Section 3(a)(2) guarantees - eligibility for MREL

Can debt securities issued under a Section 3(a)(2) bank note program where the guarantor is a branch of the issuer be deemed to meet the criteria of article 45 of the BRRD in order to be included in the amount of own funds and eligible liabilities?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2966
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 27/10/2017

Reconciliation of FINREP and COREP with regard to goodwill

May the amounts of goodwill reported in FINREP and COREP differ due to differences in treatment between the accounting framework and the CRR?

  • 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: 2016_2963
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Reporting of Treasury bills (henceforth T-bills) in template F 01.01

Where should T-bills be reported in template F 01.01 – Balance Sheet Statement?

  • 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: 2016_2962
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Risk retention and credit risk mitigation

If the Originator retains a vertical slice of a securitisation capital structure the most senior tranche of which is guaranteed - as part of the original securitisation structure - by a third party guarantor, would that be in contrast with the requirement as set out in paragraph 1 of Article 405 of CRR, providing that the net economic interest shall not be subject to any credit risk mitigation or any short positions or any other hedge and shall not be sold.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2960
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Difference between a reduction and a write-down

What is the difference between reduction and a write-down in Article 60(1)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2958
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Difference in treatment of viable subsidiaries for the application of write down and conversion of capital instruments and resolution tools and powers

Can the power of write down or conversion of capital instruments be exercised in relation to instruments issued by a still viable subsidiary belonging to a failing group?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2957
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as final Q&A: 21/01/2022

PONV write-down leaving an institution failing or likely to fail

Do capital instruments and liabilities eligible for internal MREL (minimum requirement for own funds and eligible liabilities) always have to be written down or converted through the application of the point of non-viability (PONV) write-down prior to bail-in?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2956
  • Topic: Write-down and conversion of capital instruments
  • Date of submission:
  • Published as final Q&A: 18/11/2016