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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

Recording of necessary documentation in relation to the disbursement of the loan

In relation to  46 of the EBA Guidelines on loan origination and monitoring, what is expected in relation to the 'recording of necessary documentation in relation to the disbursement of the loan', specifically in relation to adherence to the institutions' obligations towards AML/CTF requirements?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring
  • ID: 2022_6329
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

How shall open maturity repos be reported in C 81.00 and with which ASF factor ?

It is not totally clear what the term 'unless otherwise specified' in Article 428k of Regulation (EU) No 575/2013 CRR, as amended by Regulation (EU) 2019/876, means for an open repo. Does the use of the term 'unless otherwise specified' in the sentence 'unless otherwise specified in Articles 428l to 428o, all liabilities without a stated maturity, including short positions and open maturity positions, shall be subject to a 0 % available stable funding factor' mean that an ASF factor corresponding to the type of counterparty must be applied as per the article 428l to 428o CRR first?  One answer is to allocate to the open maturity repo an ASF factor based on the counterparty as for the other kind of liabilities, thus 50% for non financial counterparties and 0% else, considering the open maturity repos are in the first bucket 0-6 months. An alternative is that articles 428l to 428o CRR are only valid for deals with a maturity and thus the ASF factor should be 0% whatever the type of counterparty.  About the reporting C 81.00, in the first case, the proposal is to report the open repo with other liabilities of the same counterparty type, thus potentially in section 2.3 for non-financial customers or section 2.5 for financial ones to keep coherence on the ASF factors. For the alternative, the open repos must be reported in 2.9.4 as specified in the ITS. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6328
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

CCF used for commitment performance bond

Which CCF must be applied to the undrawn/unissued amount if there is a commitment to a performance bond facility?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6327
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

C 14.00 - Column 0222: % of retail exposures in IRB pools

Is Column 0222 in C 14.00 (% of retail exposures in IRB pools) supposed to be reported for all securitisation positions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6324
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/06/2023

Real estate inspection for real estate valuation

What does the term 'valuer' mean? In particular, does it mean only a certified person? Will it be in line with the EBA guidelines if the inspection is done by non-certified assistants, sub-assistants, real estate agents, or even the real estate owner (owner takes pictures and sends to valuator)?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring
  • ID: 2021_6325
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/06/2022

C 24.00: Capital multipliers due to model limitations

Which is the correct way to report add-ons to the Own Funds Requirements in COREP C 24.00 (MKR IM) required by the regulator due to limitations of internal models?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6323
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Approval to exclude IPS exposures from the Leverage Ratio exposure measure.

It is not clear from the instructions whether a specific approval from the competent authorities is necessary to exclude IPS exposures from the leverage ratio exposure measure or the approval referred to in article 113(7) of CRR is sufficient.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_6322
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2022

Authentication procedures that ASPSPs’ interfaces are required to support (using re-direction)

In a pure redirection-based approach, can an ASPSP, which is not offering a mobile web browser to its PSU’s, decide not to support  an authentication via a mobile web browser authentication page (no app-to-mobile web browser or mobile web browser-to-mobile web browser  redirection) for PISPs/AISPs on the basis of duly justified security risks, without being considered a breach of Article 97 (5) PSD2 and Article 30(2) of the RTS on SCA and CSC and/or an obstacle under Article 32(3) of the RTS on SCA and CSC?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6321
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 27/01/2023

PISP’s access to payable charges applied by the ASPSP on the PSU’s initiated payment via the ASPSP’s dedicated interface

Shall the account servicing payment service provider (ASPSP) make the transaction fees accessible to payment initiation service providers (PISPs) via the dedicated interface?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6320
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

Disclosures Relating to Trading and Non-Trading Book Clients

When firms calculate exposure value in line with K-TCD, firms carry it out at client level, taking the replacement cost and PFE for each client and each product.  Firms then net exposures against collateral in line with Article 31 of IFR.   Assuming that an appropriate netting agreement is in place with the client, available collateral is deducted to arrive an exposure value for each client. Where clients have both trading book and non-trading book exposures, and the netting agreement in place provides that the collateral held is fungible i.e. there is no particular collateral assigned to the trading book or non-trading book contracts or transactions, for the above reporting schedules a methodology to apply the collateral between trading book and non-trading book exposures is required.  

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6319
  • Topic: Supervisory Reporting - IFR Reporting framework
  • Date of submission:

Future-dated payments and recurring transactions

When it comes to recurring transactions and future-dated payments, would an implementation of the PSD2-interface that requires that the TPPs store the payment details until due date, and not until due date are they allowed to send the transactions to the ASPSP for execution, satisfy the requirements in Opinion on the implementation of the RTS on SCA and SCA (EBA-Op-2018-04) of June 13, 2018' paragraph 29, in cases where the ASPSP itself offers future-dated payments and recurring transactions in their mobile/web-bank application? If the answer to the preceding question is yes, what then is the meaning of the statement '… a PISP has the right to initiate the same transactions that the ASPSP offers to its own PSUs, such as … recurring transactions, … and future-dated payments'?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6318
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/10/2022

Amount of certain CET1 items available for stable funding

For the purposes of calculating available stable funding, it is unclear what amount should be reported, if any, as regards the following CET1 items: a) retained earnings, b) minority interests and c) amounts added back to CET1 due to the application of IFRS 9 transitional arrangements (Article 473a CRR).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6317
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Scope of COH definition under IFR

Are pure intermediation transactions processed in name give-up taken into account in the K-COH calculations?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6316
  • Topic: K-factor requirements
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Transactions initiated via electronic mail (email)

Do transactions initiated via electronic mail (email) qualify as initiations pursuant to Article 97 para. 1 (b) PSD2 and are therefore subject to the RTS SCA requirements?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6315
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/01/2023

Validation rule v09753_m

Should the validation rule v09753_m  be adapted for column 0060 “Number of obligors”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6314
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2022

Deactivating Validationrule v10549_h

The validation rule v10549_h should be deactivated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6313
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

FINREP - Validation rules EBA_v10610 on F18.0

During the last reporting of 30/06/2021 and 30/09/2021 we received a return from ACPR about the validation rule EBA_v10610 on F18.0. The message is : "Failed XBRL rule v10610_m: [F 18.00.a (r0005;0010;0020;0030;0040;0050;0060;0070;0080;0090;0100;0110;0120;0130;0140;0150;0160;0170;0180;0181;0182;0183;0184;0185;0186;0191;0192;0193;0194;0195;0196;0900;0903;0197;0910;0913;0201;0330;0335)] {c0020} = {c0056} + {c0057} + {c0058}" We think the check is wrong on row 330. On this row, column 020 is the sum of rows 0180 + 0201 + 0231. Line 0231 corresponds to DEBT INSTRUMENTS AT STRICT LOCOM, OR FAIR VALUE THROUGH PROFIT OR LOSS OR THROUGH EQUITY NOT SUBJECT TO IMPAIRMENT or which the Finrep does not request a breakdown on the columns 0056 + 0057 + 0058.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6312
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2022

Calculation of NPE ratio and coverage of NPEs with accumulated impairment and collateral following changed definition of gross carrying amount of debt instruments at fair value through other comprehensive income (in continuation: debt instruments at FVOCI) from "carrying amount before adjusting for any loss allowance" to "the amortised cost before adjusting for any loss allowance"

Should enter into calculation of NPE ratio and coverage of NPEs with accumulated impairment and collateral in case of debt instruments at FVOCI   "carrying amount before adjusting for any loss allowance" or "the amortised cost before adjusting for any loss allowance"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2021_6311
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2022

Reporting of specific information concerning template C106.01: “Instrument 23”

Our issue and its corresponding question rely on the manner we should report a specific information concerning the template C106.01 “SBM.Risk sensitivities by Instrument” – 2022 benchmarking exercise – based on a constraint of this template regarding the number of lines we can report. That is: “Institutions shall report each combination of Instrument number, Risk identifier (column 0010), Bucket (column 0020) and Additional identifier (column 0030) only once.” Our doubt is linked to the “instrument 23” and to the new benchmarking sensitivities’ template submission. Concretely, we have received a validation due to a negative volatility we reported within the template. The reason is that “instrument 23” Collar component is based on two transactions: a 7.5% Cap and a 2.5% Floor. The Vega Net sensitivity of both transactions (therefore, the Collar Vega sensitivity) is positive, even though one of the transaction’s Vega is positive while the other one is negative. Since the Collar figures must be reported only with one “line”, it forces us to reach a negative Collar FRTB-SA weighted Vega value with the multiplication of a positive Collar Vega sensitivity and a positive “average” volatility, which mathematically speaking is not possible.

  • 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: 2021_6310
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 23/09/2022

MREL/TLAC EBA template – split of liabilities by creditor hierarchy

Does the maturity split of own funds and potentially eligible liabilities for MREL in template M 06.00 of the ITS on disclosure and reporting on MREL and TLAC include prudential filters or not?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2021_6309
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2023