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List of Q&A's

Reporting requirements for template C 33.00

How shall exposures to entities that are classified differently between different reporting frameworks (i.e. FINREP and COREP) be assigned to an exposure class in Template C33?

  • 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_3424
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Investment firms’ exposures to credit institutions

Should MIFID investment firms which are subject to the CRR calculate the credit risk requirement for the clients’ funds (i.e. cash) deposited in a credit institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3422
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

Potential inconsistency between articles 68 and articles 69 through 71 in what concerns exemptions.

Considering contracts involving central counterparties and central banks are exempted from Member States' powers (i) "to suspend certain obligations" (69), (ii) "to restrict the enforcement of security interests" (70) and (iii) "to temporarily suspend termination rights" (71), are such organizations exempted from the "exclusion of certain contractual terms in early intervention and resolution" (68)? Example: if a crisis prevention measure is taken in relation to an entity with which a central counterparty or a central bank has a bilateral agreement, would the central counterparty or central bank be able to immediately exercise its contractual termination rights on the grounds of the referred intervention?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3421
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Validation rule (taxonomy 2.6) e4902_n about the risk weighted exposure for Equity in CR SA

Where shall equity exposures treated according to Articles 48(4), 471(2) and 495 (1) CRR be reported in COREP CR SA (C 07.00)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3414
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Reporting of assets credit-impaired at purchase within template F 04.03.1 and F 04.04.1

How shall row 190 (columns 015-070) within template 4.3.1 be filled in order to fully comply with, in our interpretation, contradictory attributes stated in the terms of both rows and columns?

  • 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_3410
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Treatment of claims secured on residential property collateral

As claims secured on residential property collateral are excluded from the calculation of the total amount owed, can the deduction factor be applied to these claims secured on residential property collateral even though the remaining total amount owed by the obligor (group) exceeds the EUR 1,5 million? Or does it mean that once the remaining amount owed exceeds the limit all claims by the same obligor (group) are not eligible for the deduction?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3404
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Incorrect validation rules v4779_m and v4782_m

The question relates to the validation rule 4779_m and v4782_m implemented in DPM 2.6 and 2.7. Currently these validations are applied to all figures reported on rows 110 and 070 for all sheets and all columns. But as columns 080, 090 and 100 are used to display weighted PD or LGD, those columns must be excluded from validations v4779_m and v4782_m.Having a weighted PD of 52% on SME and a weighted PD of 50% on non SME doesn’t mean that the global weighted PD of the ‘Secured by real estate property’ will be of 102%. The global PD for such exposure class will be between 50 and 52%. If you agree, even if this rules are non-blocking, can you please deactivate them? And correct them for the next release?

  • 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_3400
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/12/2017

Reporting of credit quality step where no rating is present

If no rating is present for counterparties reported in C71, step 'non-rated' or "CQS other" should be reported?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3399
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

New EBA Validation rule (taxonomy 2.6) v4786_m about the comparison between the risk weighted exposure amount and the exposure value for Equity in CR GB IRB

According to the validation rule v4786_m, c105 shall be greater than or equal to c110 in all rows and all sheets in C 09.02, i.e. the exposure value (c105) has to be higher than the risk weighted exposure amount (c110).However, in accordance with Article 155 paragraph 2 of the CRR, the risks weights are equal to 190% for private equity exposures in sufficiently diversified portfolios, 290% for exchange traded equity exposures and 370% for all other equity exposures.For the row 140 ‘Equity’ in template C 09.02, as these rates are higher than 100%, the exposure value can be less than the risk weighted exposure amount and the rule cannot be respected.Could you please exclude the rows 140 ‘Equity’ and 150 ‘Total Exposures’ from the 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)
  • ID: 2017_3394
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/12/2017

C 09.04, row 40, column 010 - Value of trading book exposures for internal model

Regulation 2016/1702 requires that row 40 only be populated with the exposures value for relevant credit defined in Article 140(4)(b) of Directive 2013/36/EU (CRD), in accordance with Article 104 CRR, namely the sum of the following items: -Fair value of non-derivative positions; -Notional value of derivatives. We remain unsure how the bank should include short positions in the reported exposures. Question: Could you indicate how the bank should include short positions in the reported exposures?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3391
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Precisions on the Entity Code on COREP Solva Group (C06.02) and FINREP F40.01

Is the EBA expecting a specific relation between the column 020 in the COREP C06.02 and the column 020 of the FINREP F40.01 template ? The annexes 2 (solvency) and 5 (FINREP) of the regulation 680/2014 do not bring any information regarding an expected accordance, and only indicate that the code should be unique for each line of the template. However, those codes seem to have the same purpose, and the same entities are likely to be reported on those templates on each remittance. Therefore : - Is an entity reported in both C06.02 and F40.01 supposed to share the same code on the columns 020 of the both templates? - Is an entity reported in one of those templates supposed to share the same code in the next remittance of the template? Similar questions can be asked regarding the columns 010 of the large exposures templates (C27 to C31).

  • 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_3390
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Validations between F 13.01 and F 05.00

Are validation rules v1076_m, v1079_m, v1082_m and v1085_m correct and applicable in all cases?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 625/2014 - RTS on requirements for investor, sponsor, original lenders and originator institutions of transferred credit risk exposures
  • ID: 2017_3379
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

EBA validations rules for 2.5 with reference v2708_m and v3091_ m

In accordance with Annex V.Part 2, paragraph 162 the sum of the amounts reported for both collateral and financial guarantees shall be capped at the carrying amount of the related exposure. Does the carrying amount of the related exposure refer to the gross carrying amount of the related exposure (before accumulated provisions) or to the net carrying amount (after provisions).

  • 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_3377
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/11/2017

Proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU as off-balance sheet exposures

Are the binding proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU off-balance sheet exposures according to Annex I CRR?Should FINREP,COREP reporting include such binding proposals for mortgage credit extension?

  • 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_3376
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Use of Maturity Mismatch for Exposures arising under Master Netting Agreements

Do the requirements to adjust the value of collateral for maturity mismatch (Article 239) apply when using the supervisory volatility adjustments approach for Master Netting Agreements under Article 220?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3375
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Reserves of Equity Accounted Entities

How should dividends received by the reporting entity from an equity accounted entity be classified in the equity rows of Template 1.3 and Template 17.3 ?

  • 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_3374
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Criteria for sufficiently diversified private equity portfolios under the simple risk weight approach

What rules should be applied in assessing whether a private equity exposure is in a sufficiently diversified portfolio of portfolio companies as mentioned in Article 155(2)?In case of exposure to several private equity funds, may the portfolio companies of these private equity funds be considered as one portfolio before assessing whether the portfolio is sufficiently diversified?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3371
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Treatment of changes in deposit balances due to changing exchange rates in AMM template C 69.00

In the event that the original currency balance of a non-GBP deposit balance does not change from the prior reporting period reference date to the current reporting period reference date, but the GBP exchange rate changes, so that the reporting currency balance at the current reporting period reference date shows an increase on the prior period, should this increase be reported as new funds in AMM C 69.00?- Section 1.4.1 of Annex XIX referring to legal references and instructions for template ‘Prices for Various Lengths of Funding (C 69.00)’ requires ‘transaction volume and prices paid by institutions for funding obtained during the reporting period and still present at the end of the reporting period’.- It is unclear from the guidance whether upward revaluation of non-GBP funding into reporting currency from one reporting reference date to the next should be regarded as ‘funding obtained during the reporting period’.

  • 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_3370
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/12/2019

FINREP IFRS 9, F 16.01 - Interest income and expenses by instrument and counterparty sector

Under national GAAP based on BAD, do ‘impaired assets’ consist of assets subject to specific and general impairment allowances or only those subject to specific impairment allowances? What scope of ‘impaired assets’ shall be considered for row 280 (‘of which: interest-income on credit impaired financial assets’) of template F 16.01?

  • 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_3369
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/11/2017