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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

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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3335
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as final Q&A: 11/09/2020

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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3334
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

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
  • ID: 2017_3332
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/11/2017

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
  • ID: 2017_3330
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/08/2018

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
  • ID: 2017_3329
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 03/11/2017

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
  • ID: 2017_3322
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

C 14.00 (SEC DETAILS) - column 050

Column 050 of C 14.00 – Accounting Treatment:Is this field also relevant for sponsor positions?What should be reported here for synthetic and traditional originator positions?

  • 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_3320
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Gross carrying amount of financial instruments measured at FV through other comprehensive income

Clarification of gross carrying amount of financial instruments measured at FV through other comprehensive income defined in Annex V in Final draft ITS amendments due to IFRS 9.

  • 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_3318
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

V4835_m - C 19.00 column 610 calculation

We have interrogations about the new validation rule v4835_m. In C 19.00, row 010: column 610 = column 600 (TOTAL OWN FUNDS REQUIREMENTS = SUM OF WEIGHTED NET LONG AND SHORT POSITIONS).Until now, some of our clients calculates column 610 multiplying column 600 by 8%. In ITS and Article 337 (4) CRR, we saw only the following precision: c600 is used to calculate c610 but there is no precision on this calculation. From 2015 onwards according to Article 337 (4) of CRR, the institution shall sum its weighted net positions, regardless whether they are long or short (column 600), in order to calculate the own funds requirements.Could you clarify the calculation of the column c610 in C 19.00?

  • 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_3317
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Permission for delta models for back-to-back positions

Does the requirement to obtain competent authorities’ permission for delta models (Articles 329(1), 352(1), 358(3) of the CRR) for the purposes of market risk capital requirements apply also to back-to-back positions? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3314
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 22/09/2017

Treatment of collateral swaps with underlying collateral pools/ baskets

In case of collateral swaps transactions involving exchange of collateral baskets where no direct link can be established between securities in underlying pools, how should the securities be allocated to the reporting rows in template C75 when reporting in main currency and in significant 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: 2017_3313
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Domestic - non-domestic distinction in Corep and Finrep

What should drive the domestic-non domestic distinction for COREP template 4.0 row 850 for the consolidated reporting of an institution with a holding company that is resident in another member state?

  • 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_3309
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

How to fill out the COREP C 28.00 for an exposure secured by an insurance wrapper?

Article 390(7) CRR and RTS 1187/2014 specify how to determine the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets. According to Article 200 CRR, insurance policies pledged to the lending institutions are eligible as Other Funded Credit Protection. As per Article 232 CRR, for banks under the Standardised Approach, the risk-weight of the original debtor is substituted with a different risk-weight ranging from 20% to 150%. Under the Standardised Approach, where an exposure is secured by a pledged insurance policy in the form of an insurance wrapper (life insurance policy ‘wrapped’ around the policy owner’s investment portfolio), how should the exposure and the collateral be reported in COREP C 28.00? Is there a difference between the Financial Collateral Simple Method and the Financial Collateral Comprehensive Method?

  • 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_3307
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/10/2019

References to items covered by a Deposit Guarantee scheme in the instructions on r070 and r090 of C 68.00

Is the text of Annex XIX in the final draft ITS 680/2014 and DPM 2.7 ITS on supervisory reporting correct when it refers to ALMM C 68.00, items 1.4 and 1.4.2 as ‘savings accounts without a notice period for withdrawal which is greater than 30 days covered by a Deposit Guarantee Scheme according to Directive 2014/ 49/ EU or an equivalent deposit guarantee scheme in a third country’?

  • 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_3306
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Definition of 'carrying amount' for the purposes of templates C 67.00, C 68.00 and C 69.00

In the guidance annexes for DPM 2.7 for ALMM returns C 67.00, C 68.00 and C 69.00 (Annex XIX) the requirement for ‘volume’ and ‘amount of funding’ has been further specified to ‘carrying amount’ for these templates only. Annex XIX does not define ‘carrying amount’ for liabilities – with reference to the ALMM templates mentioned, should it include accrued interest?

  • 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_3305
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Effective LGD

Could effective LGD (LGD*) be used both in AIRB and FIRB if the operation has an eligible financial collateral under Financial Collateral Comprehensive method?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3304
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Consideration of surplus collateral received in providing further credit risk mitigation

We are aware of differing interpretations by market participants in relation to the answers given under EBA Single Rulebook Q&A 2013_206 and 2016_2735 on the application of Collateral Received to achieve further credit risk mitigation to the extent that Collateral Received exceeds the net replacement cost, RC net.For collateral received to reduce Net Replacement Cost, RC net, can surplus collateral be used to offset the reduced potential future credit exposure, PCE red, or may EAD, RC net + PCE red be further offset by any surplus Collateral Received that has not been applied in the RC net calculation? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3303
  • Topic: Market risk
  • Date of submission:

“Past due” columns: How to count number of days for “1 year” and “5 years” past due?

In Template F 18.00 the “cross carrying amount / nominal amount” and the “accumulated impairment, accumulated negative changes in fair value due to credit risk and provisions of non-performing exposures” have to be allocated to different “past-due” columns according to its number of days past due. How many days past due have to be assumed in order to allocate an exposure to past-due column “1 year” or “5 years” respectively?

  • 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_3301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Grandfathering of own funds instruments

For application of the grandfathering rules defined in Article 484 CRR and following, does the change in debtor resulting from a merger means that a new capital instrument has been issued and that its eligibility for grandfathering or for full eligibility as an own fund instrument should be assessed at the date of the merger or should one use the initial characteristics of the bond?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3299
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 17/11/2017

FINREP Templates F 30.01 and F 30.02, validation v1019_m

For interests in unconsolidated structured entities for which no liquidity support is drawn, what is the treatment for validation v1019_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)
  • ID: 2017_3298
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 28/07/2017