Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Obligation to carry out analysis and to consult with EBA on planned increase of risk weights before RTS on this matter are finally adopted and published in the Official Journal of the European Union

Is there an obligation to carry out appropriate analysis and to consult with EBA on planned increase of risk weights since RTS on this matter are not finally adopted and published in the Official Journal of the European Union?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2894
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/02/2017

Clarification of columns 050 and 060 of template C 101.00, Annex I of the Benchmarking exercise.

In ITS-Annex I of the Benchmarking exercise the columns 050 and 060 provide the ISIN code and Bloomberg ticker, respectively. Is the requirement to report only exposures to the instruments specified by the ISIN/Bloomberg ticker or should all exposures to the counterparty be reported?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2892
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Standardised approach risk weighting

In the scenario below, if the repayment of a retail depends on the client's business (and not the performance of the property), could a loan secured by immovable commercial property have a higher RW than a similar loan which is unsecured?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2891
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Seeking clarifications/ remediation on EBA LCR specified taxonomy mapping for Annex XXIV and Annex XXV templates

We have identified a taxonomy anomaly in the EBA LCR 70s Series taxonomy that does not allow for this guidance to be implemented for collateral swaps. Unlike template C 73.00 where ‘counterparty is central bank’ shows a 0% standard weight resulting in a 0 outflow (C 73.00, r930 c040 – c060), template C 75.00 does not provide a specific row to delineate exposure to central banks. Therefore it is not possible to isolate collateral swaps with a central bank to apply 0% outflows in the current template and taxonomy construct as per guidance - Article 28.4 of Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement: ‘Collateral swaps that mature within the next 30 days shall lead to an outflow for the excess liquidity value of the asset borrowed compared to the liquidity value of the asset lent unless the counterparty is a central bank in which case a 0% outflow shall apply’.

  • 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_2890
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Reporting of of the group of connected clients in C27 Identification of the counterparty (LE1) when the national reporting system DOES NOT provide a unique code for the group of connected clients

It is unclear if the group of connected clients should be reported in C27 Identification of the counterparty (LE1) when the national reporting system DOES NOT provide a unique code for the group of connected clients.

  • 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_2888
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reporting of collective allowances for incurred but not reported losses on non-performing exposures in FINREP F 18.00 and F 19.00 templates

If incurred but not reported losses (IBNR losses) relate to a non-performing exposure, in which column should the collective allowances for IBNR losses be reported in template F 18.00 and F 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: 2016_2887
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Transactions with maturities longer than 10 years

We reference to the Q&A 2015_1802: Transactions with maturities longer than 10 years are excluded in the form C 69.00. Does the excluding of transactions with maturities longer than 10 years also apply for the form C 70.00?

  • 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: 2016_2885
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 01/12/2017

Distribution by an originator to its shareholders of a participation instrument the pay out of which is directly linked to the net cash flows under the net economic interest retained

Would a credit institution acting as originator in relation to a securitisation and holding the net economic interest pursuant to Article 6 Regulation 2017/2402 be in breach of Article 12 of Regulation (EU) 625/2014 if such credit institution decides to issue to its shareholders, free of charge, a participation instrument the pay out of which is directly linked to the net cash flows under the net economic interest retained by the originator?

  • 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: 2016_2878
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 17/02/2017

Is a tied agent of the investment firm a financial institution and should it be included in prudential consolidation

1. Should a company acting as a tied agent of the investment firm be included in prudential consolidation according to Art. 18 of CRR, if the tied agent is controlled by the same holding company as the investment firm (or by the investment firm itself)? 2. Should the company acting as a tied agent be included in the prudential consolidation a) because it is an ancillary services undertaking in accordance with Art. 4(1) point 18 of CRR, b) because it is a financial institution in accordance with Art. 4 (1) point 26 of CRR, or c) because of some other justification to require the consolidation, or d) should it not be consolidated at all in accordance with Art. 18(1) nor (8) of CRR.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2875
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

COREP C 17.00 - operational risk / losses to be reported

In COREP C 17.00, is there a definition of which losses have to be reported related to usury and compound interest? Our bank also includes losses here that are linked to credit risk (to be more specific: fraud linked to credit risk). Although fraud is indeed covered by COREP C 17.00, we understand the underlying rules of COREP C 17.00 to be "operational losses only". However, we are unsure what the correct interpretation of "operational losses" is here. For the determination of capital requirements, should these credit-risk related fraud losses be captured within the operational risk (so COREP C 17.00) or within the credit risk?

  • 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_2874
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Contributions to the financing arrangements from ceased banks

Do institutions that cease to exist or to be supervised in a given year prior to the determination or raising of the annual contributions still have to contribute to the financing arrangements?

  • 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_2872
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Cap on inflows for consumer finance or leasing and factoring activity

When a bank constituting a single liquidity subgroup is applying for a preferential treatment in accordance with Article 33(3) or Article 33(4) of the LCR Commission Delegated Regulation (EU) 2015/61 at consolidated level, does Article 33(5)(b) of the LCR Commission Delegated Regulation (EU) 2015/61 refer to the balance sheet value of the individual entities or to the consolidated single liquidity sub-group?Also, when assessing a request in accordance with Article 33(3) or Article 33(4) of the LCR Commission Delegated Regulation (EU) 2015/61 at individual level, is it possible to exclude some components of the total balance sheet when checking if the ratio ‘activities as referred to in Article 33(3) over total activity’ or ‘activities as referred to in Article 33(4) over total activity’ exceeds 80% of the total balance sheet (e.g. shareholdings in subsidiaries performing the same activity, refinancing agreements toward these subsidiaries)?

  • 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: 2016_2870
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 14/07/2017

Definition of "total liabilities"

Does the reference to ‘total liabilities’ in Article 3(11) of Commission Delegated Regulation (EU) 2015/63 mean liabilities and capital, or only liabilities?

  • 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_2869
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Template C 17.00 (OPR DETAILS) – Reporting of loss adjustments

How should a positive or negative loss adjustment be reported in template C 17.00 of Annex I of Regulation (EU) 680/2014 (ITS on Supervisory Reporting)? In particular, how should it be reported in the loss-size buckets (rows 920 – 924 of 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: 2016_2867
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Clarification of the collateral amounts

Could you please clarify the amounts which need to be reported in column 150-210 of template C08.01 for funded credit protection and where the institution uses its own LGD estimates? Is this the value which is used in the LGD estimation (taking into account article 181 (1) (e) and (f)) or is it solely the estimated market value (without any haircuts)?

  • 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_2866
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Rating of subsidiaries

Is “separately rated” in Article 172(1)(d) to be interpreted as “rated on individual information” or as ”having own rating based on a separate rating process”? Alternatively put: How is “separately rated” in Article 172(1)(d) to be interpreted?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2864
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reporting of CCF values for FIRB

Instructions on c100 of C 103 in ANNEX IV to the ITS state that institutions should report own estimates for CCFs. If the institutions apply the FIRB approach, they have to use regulatory CCFs. Further, in the case that there are no off-balance positions in the exposure no CCF is applied. Would it be correct to report regulatory CCFs if no own estimation is undertaken or should these cells be left blank? If no CCF is applied, should the cell be left blank or be filled with a 1cnot applicable 1d?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2016_2861
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Application of the Guidelines on sound remuneration policies to the award and pay out of variable remuneration for the performance year 2016

In the Guidelines the application date is set for 1 January 2017. Do the Guidelines apply to variable remuneration for the performance year 2016 that will be awarded in 2017?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2016_2858
  • Topic: Remuneration
  • Date of submission:

Determination of proxy spreads for the calculation of CVA risk under the advanced method

1. Does Article383 (1) CRR in connection with regulation 526/2014 (RTS) in principle allow to waive one or more of the attributes of rating, industry and region when determining a proxy credit spread for the advanced method for the determination of own funds requirements for credit valuation adjustment (CVA) risk? 2. What is the minimum granularity (number of categories) that a credit spread proxy must reflect to be appropriate with respect to the attributes of rating, industry and region of the counterparty?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 526/2014 - RTS on proxy spread and limited smaller portfolios for CVA risk
  • ID: 2016_2856
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Calculation of the predetermined amount for market making purposes

Which amount has to be taken into account in market making operations when the nominal amount of the repurchased CET 1 instruments , e.g. shares, is 1 EUR per share but the current market price which has to be paid for the repurchase of the share is higher, for example 20 EUR. Which amount has to be taken into account to compute the predetermined maximum amount for market making purposes for which a general prior permission has been granted by the competent authority (CA) according to the second subparagraph of Article 78(1) of Regulation (EU) No 575/2013 (CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2016_2852
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 09/12/2016