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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

Exclusion of centrally cleared transactions

How should the terms ‘clearing member’ and ‘client’ be understood for the purposes of Article 382(3) of Regulation (EU) No 575/2013 (CRR)? In Article 382(3) CRR, are clients’ transactions excluded from the perspective of the client only or from both perspectives of the client and the clearing member?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3009
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Rating grades in Annex I of the draft ITS on benchmarking

Please confirm the approach to be applied regarding the master scale.According to us, two options seem possible:Case 1: use only the necessary number of proposed available rating grades of the annex 1 (e.g. in case we have 30 different non defaulted values in our master scale, we would map them with the 30 first rating grades of the annex 1)Case 2: distribute the internal master scale on the whole range of the proposed rating grades of annex 1 (e.g. in case of 30 different non defaulted values in our internal master scale, "internal_rating_1" = "rating 1", "internal_rating_2" = "rating 4", "internal_rating_3" = "rating 7", ... , "internal_rating_30" = "rating 99").This should allow a more homogeneous distribution of the different master scales of the institutions in the regulatory proposed master scale from "rating 1" to "rating 99".

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2016_3002
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Collateral value

Please confirm that the sum of all the collateral values of all the collateral types of all exposures of a given counterparty should be provided?Remark: this sum will be split between the types of risk where relevant according to the corresponding counterparty codes of the given counterparty.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2016_2999
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017

EBA validation rule (Leverage Ratio) v4456_m

We think that the validation rule v4456_m may not be correct because the first part is deducting row 260 of C 47.00 “(-) Exposures exempted in accordance with Article 429(14) of the CRR”. However, the exposures included in C 47.00 row 260 are reported in C 43.00 row 090 “Exposures treated as sovereigns” which is added in second part of the validation rule. v4456_msum({C_47.00, c010, r[010, 020, 030, 040, 050, 060, 070, 080, 090, 100-260]}) = sum({C_43.00.a, c010, r[010, 040, 050, 060, 065, 070]}) + sum({C_43.00.b, c010, r[080, 090, 140, 180, 190, 210, 230, 280, 290]}) + sum({C_43.00.c, c020, r[080, 090, 140, 180, 190, 210, 230, 280, 290]})Should it be changed this validation rule in the following sense?sum({C_47.00, c010, r[010, 020, 030, 040, 050, 060, 070, 080, 090, 100-260]}) ≤ sum({C_43.00.a, c010, r[010, 040, 050, 060, 065, 070]}) + sum({C_43.00.b, c010, r[080, 090, 140, 180, 190, 210, 230, 280, 290]}) + sum({C_43.00.c, c020, r[080, 090, 140, 180, 190, 210, 230, 280, 290]})

  • 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_2997
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Financial Customers

When assessing the primary activities of any legal entity to assess whether these activities fall within the list of activities that define an entity as a "financial customer" (Annex I), should the activity of the entity being assessed include intragroup activity with other controlled entities within the same group or should intragroup activities with other controlled entities within the same group be excluded?

  • 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_2996
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 21/01/2022

IMV definition for 2017 Market Risk Benchmarking exercise

In Annex V.b it is stated that the Initial Market Value (IMV) means the 'unrealized balance'. Institutions seek more guidance in how to apply this. Should it be the mark-to-market on 27 October 2016, or the difference between the MtM's of 27 October 2016 and 13 October 2016?

  • 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_2993
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Reporting of assets lending on an unsecured basis

When collateral lending on an unsecured basis maturing within the 30-day period, shall the institution report this as inflows?

  • 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_2992
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 16/06/2017

Incentives to redeem of a hybrid instrument with a call for grandfathering purposes

Article 489 of Regulation (EU) No 575/2013 (CRR) provides for the grandfathering treatment of hybrid instruments with a call and an incentive to redeem. A bank has issued a bond with a fixed coupon before the first call date and a floating rate coupon after the first call date. The credit spread of the fixed coupon as of the issuance date is the same as the margin of the floating rate coupon after the first call date, so there is no immediate step-up there. However, the floating rate coupon is floored at the level of the fixed rate coupon. Does this constitute an incentive to redeem ?

  • 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_2988
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 17/02/2017

Calculation of distributable items for Additional Tier 1 instruments which is inconsistent across the EU

Art. 52 (1)(l)(i) Regulation (EU) No 575/2013 (CRR) refers to ‘distributable items’ as defined in Art. 4 (128) CRR which refers further into applicable national law and the statutes of the institution. Does such reference also consider items that are non-distributable under applicable national law or the statutes of the institution only for common stock or, alternatively, only following a net assets or insolvency related test?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2987
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Prudential treatment of extraordinary ex-post contributions to resolution funds pursuant to Article 104 of the BRRD

Can the extraordinary ex-post contributions to resolution funds provided for by Article 104 of the BRRD be considered as any of the off-balance sheet items mentioned in Annex I of the CRR ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2985
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Pillar 3 Disclosure Requirements for Standalone Solo Banks with a Third Country Parent

Can a solo subsidiary bank located in member states which have a parent located in a third country avail of the CRR exemption set out in Article 13(3) of Regulation (EU) No 575/2013 (CRR) not to apply (in full or in part) the pillar 3 disclosure requirements set out in Part 8 to the extent that they are included within equivalent disclosures provided on a consolidated basis by a parent undertaking established in a third country?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2984
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of "managerial (internal business) purposes" in terms of re-developed IRB model application.

Is there a definition of “internal business purposes” and a list of activities which are considered eligible for internal business purposes in Annex I, Part II, Section 2, paragraph 6 of Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)? Are there any impediments to the usage of re-developed IRB models for managerial/internal business purposes?

  • 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: 2016_2983
  • Topic: Model validation
  • Date of submission:
  • Published as final Q&A: 12/05/2017

Reporting of deductions of receivables assets for cash variation margin provided in derivatives transactions in LR4 (C43.00)

In which row(s) shall the receivables for cash variation margin provided in derivatives transactions 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: 2016_2982
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting template C40.00 (LR1): Validation rules v0101_h and v0102_h should be amended

Should column 070 of C40.00 be exempted from the application of validation rule v0101_h and v0102_h?

  • 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_2981
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Application of the risk indicators in specific cases - Liquidity sub-group

How to apply waivers granted by NCA in accordance articles 8 and 21 of CRR (liqiudity requirements / liquidity sub-group) with regard to NSFR when calculating ex ante contributions to resolution financing arrangements for particular firms?

  • 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_2975
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Reported currency by issuer/counterparty on a total level (in the Total sheet)

How should assets that are issued or liquidity lines that are granted by a single issuer / counterparty be reported in the Total sheet, provided that the asset received or undrawn committed liquidity lines granted to the institution are denominated in more than one currency? Should the issuer / counterparty be reported on separate lines for separate currencies, or should the currency in which the largest proportion of assets / liquidity was obtained be reported for the aggregated 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: 2016_2974
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

Asset encumbrance template F32.04 Sources of Encumbrance – Reporting, on individual basis and consolidated basis, of “Source of encumbrance” for securitisations.

What should be reported, on an individual basis and on a consolidated basis, as source of encumbrance in case of securitisations in which the securitised assets remain in the balance sheet (i.e, they have not been derecognised)? “Debts securities issued, of which: asset back securities” or “Collateralised deposits other than repurchase agreements”?

  • 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_2972
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Treatment of an institution’s guarantees for investments into CIUs

In case of an institution’s guaranteeing the amount of a customer’s original investment into a CIU and a minimum yield:1. To which risk category for off-balance sheet items in Annex I CRR shall these guarantees be assigned, in particular shall this assignment depend on any risk mitigation techniques used by the CIU?2. Shall these guarantees be treated as an exposure in the form of units or shares in a CIU, which would in particular allow the institution to look-through to the underlying exposures of the CIU, provided the conditions for looking-through are met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2971
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/10/2017

F 05.00, row 010, column 030 - On demand [call] and short notice [current account] for Central Banks

For template F 05.00 relating to the breakdown of loans and advances by product, Annex V, Part 2.41 states that: ‘balances receivable on demand classified as ‘Cash and cash balances at central banks’ shall also be reported in this template ‘. Besides the cash and cash balances there are also compulsory reserves that have to be reported in this template. In which row do they have to 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: 2016_2970
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 28/07/2017

Interpretation of Article 88(1) and 89(1) BRRD with respect to the scope of resolution colleges for third country institutions or third country parent undertakings

Is an Article 88 resolution college required for a subsidiary of a third country parent undertaking where that subsidiary itself has subsidiaries in other Member States? If so, is an Article 89 European resolution college also required? In particular, where there is an unrelated sister subsidiary of the third country parent undertaking in another Member State, will both an Article 89 BRRD European resolution college (covering the entire presence of the third country parent undertaking in the Union) and an Article 88 BRRD resolution college (covering any subsidiary which itself has subsidiaries in other Member States) need to be established?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2969
  • Topic: Cross-border resolution
  • Date of submission:
  • Published as final Q&A: 10/02/2017