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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

Extending the range of application system.

What is practically meant by 'additional exposures related to the lending decision of a third party to the group'?

  • 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: 2015_2224
  • Topic: Model validation
  • Date of submission:
  • Published as final Q&A: 23/09/2016

Promotional banks

Is there a list of all EU institutions qualifying for the notion of "promotional bank"?

  • 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: 2015_2223
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 01/07/2016

Liquidity – treatment of payment commitments according to Article 2 (13) DGSD

How should payment commitments pursuant to Article 2(13) DGSD (Directive 2014/49/EU) be treated in the outflow-section of LCR?

  • 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: 2015_2222
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/05/2016

FINREP, F 31.02 vs F 02.00 – dividend income from joint ventures and associates

Could you clarify the inconsistency between the references of template F 31.02 (IAS24) and the instructions and deactivate the validation rule v1374_m, or if not, clarify the reasons of this one?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2015_2218
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Mortgages as the real estate collateral received to be included in template AE-COL

Following the answer provided on Q&A 2013_675 we would like to clarify if mortgages as the real estate collateral received should be included in template AE-COL. If so, in which column / row should it 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: 2015_2217
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Consistency between validation rule V3933 and paragraph IAS39 - 89A

Could you explicit the reasons of the validation rule V3933, taking account of paragraph IAS39 - 89A, mentioned in the template?

  • 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: 2015_2215
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Prices for various lengths of funding - Transactions volume

Should transactions volume in Prices for Various Lenghts of Funding be reported as average transactions volume, calculated as total volume divided by number of transactions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_2208
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Reporting of prices for various lengths of funding

Should Reporting of Prices for Various Lenghts of Funding include only those transactions originally in Euro currency, excluding all other different currencies?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2015_2204
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Treatment of securities received in reverse repo and sold (short position) in F32.04 and F08.01

Our question is about the link between F32.04 and F08.01 for reverse repo, notably if the securities received is sold (short position). Our position is: - Securities in reverse repo don’t have to be reported in F 8.1 (only repo have to be reported) but should be mentioned in cell 160_030 in F32.04, - Securities received and sold have to be reported in F 8.1, cell 040_010, - The sum of row 10 to 110 (column 010) of F32.04 have to be matched with liabilities reported in F08.01. Do you agree with this treatment? If not, could you precise your recommendations?

  • 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: 2015_2202
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Scope of application of FINREP

Pursuant to article 99.2 CRR, institutions subject to Article 4 of Regulation (EC) No 1606/2002 and institutions other than those referred to in Article 4 of that regulation that prepare their consolidated accounts in conformity with the IFRS/IAS shall also report financial information. Shall an institution publishing its consolidated accounts in IFRS submit the reporting FINREP at its level when it is controlled by a parent financial holding company? It is worth noting that this institution applies the own funds requirements on the basis of the consolidated situation of the financial holding company in accordance with the article 11.2 of the CRR, and not on the basis of its own consolidated accounts. In addition this institution is not subject to own fund requirements at its level either on a sub-consolidated or on an individual basis.

  • 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: 2015_2201
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Classification of a performance bonds according to annex 1.

Does a performance bonds which guarantee satisfactory completion of a project by a contractor with an original maturity of more than one year qualify as Medium/low risk according to CRR, annex I, item 3(a)(ii) ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2198
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/06/2016

Potential Future Exposure (PFE) add-ons for written options out side netting agreement

Is PFE (Potential future exposure) calculation applicable for written options when they are included in derivative netting and not applicable for written options when there is no netting agreement?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2195
  • Topic: Market risk
  • Date of submission:

Definition of large financial sector entity

In applying the definition of “large financial sector entity” under Article 142(1)(4)(a) of Regulation (EU) No 575/2013, is it correct to consider the assets of the counterparty (individual or consolidated balance sheet), rather than consolidated assets for any Group to which the counterparty belongs?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2193
  • Topic: Model validation
  • Date of submission:
  • Published as final Q&A: 11/03/2016

Information on performing and non-performing exposures

Table F 18.00 of FINREP contains the breakdown by past-due time bands of performing and non-performing exposures. In case of "debtor approach" how should the exposures to a given debtor be allocated to columns? And do such criteria have to be applied to both performing and non-performing debtors?

  • 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: 2015_2192
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Small bank: bail-in or liquidation

Should the resolution authority assess the possibility of bail-in even for a small non-systemically important institution without critical function before making a decision about liquidation?Please specify whether in the scope of Article 31(2)(e) "client funds and client assets" should be included also moneys of bank's depositor (creditor) exceeding the covered deposit?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2191
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 26/10/2018

Wrong validation rule v2855_m

Is a netting of repurchase agreements with securities lending needed in Asset Encumbrance?

  • 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: 2015_2190
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 13/12/2019

Final valuation lower than the initial valuation

What are the consequences of final valuation being lower than the initial one?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2187
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Same valuer for provisional and final valuation

Can the resolution authority outsource the provisional valuation? If yes can the same valuer prepare provisional and final valuation?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2186
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Clarification on the role of the special manager in resolution

We seek clarification on the role of the special manager in resolution as set out in Article 35 of Directive 2014/59/EU (BRRD). This appears to overlap with the role of the temporary administrator as defined in Article 29.Also, is the special manager referred to in Article 35 BRRD a separate institution from that mentioned in Article 72(1) or only its special case?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2185
  • Topic: Special management
  • Date of submission:
  • Published as final Q&A: 11/11/2016

Liability in the context of special management

In the case of special management, is the resolution authority liable for the acts of the special manager that the former had appointed and / or is the appointed special manager directly liable for their acts?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2184
  • Topic: Special management
  • Date of submission:
  • Published as final Q&A: 21/01/2022