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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 liabilities from the bail-in tool

Can the ability referred to in Article 44 (3) of Directive 2014/59/EU (BRRD) be exercised towards bail-inable liabilities or also to relevant capital instruments?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2433
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 30/10/2015

Variable component of the remuneration of material risk takers

What types of liabilities are excluded from the exemption under Article 44(2)(g)(i)is by the reference to Article 92(2) of Directive 2013/36/EU (CRD) in the second subparagraph of Article 44(2) of Directive 2014/59/EU (BRRD)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2432
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Reference to paragraph 8 in Article 41 (9)

To which obligation under paragraph 8 is Article 41 (9) of Directive 2014/59/EU (BRRD) referring to (the one provided under the first or the second paragraph? If it were the case that Article 41 (9) provides that when a bridge institution is used for the purpose of transferring assets and liabilities of more than one institution under resolution the insolvency proceedings shall refer to the assets and liabilities transferred from each of the institutions under resolution and not to the bridge institution itself, what does that really mean?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2431
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Annex V portfolio clarifications

Annex V - portfolio 1.12. The October index has not yet been published. Which index should firms use? Annex V - portfolio 1.13. Is the Option expiry date 15 January 2015?

  • 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: 2015_2430
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Exit criteria from non-performing forborne category

According to paragraph 157 of Annex V, a condition to exit the non-performing forborne category is that a period of (at least) one year has passed since the forbearance measures were applied (“cure period”). During this period, there must not be any past-due amount or concern regarding the full repayment of the exposure according to the post-forbearance conditions. If an amount due is unpaid during the “cure period”, the latter shall be considered as “discontinued” or “suspended”? In the former case, the counting of the year should restart from the date of any repayment; while in the latter case, the counting of the year shall continue since the date of any repayment.

  • 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: 2015_2429
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Conditions for Resolution

At what point of time during a resolution procedure must the conditions for resolution pursuant to Article 32(1) BRRD be met? Is it necessary to only positively assess them at the initiation of the resolution process, i.e. at the moment the resolution authority initiates a resolution procedure?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2428
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 22/07/2016

Corporate Treasury Entities

How should a non-banking entity within a non-financial group set up to act as a central corporate treasury function be classified for the purposes of LCR?

  • 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: 2015_2426
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Deposits reported in P 01.02 and in P 02.01

This question aims to clarify the validation rule v4134_m of the Funding Plan template. This validation rule states that the total deposits reported under "P 02.01 - Insured and uninsured deposits" must be equal or smaller than the deposits reported on lines 020, 060 and 120 of the frame "P 01.02 - Liabilities". Due to several reporting issues we intend to clarify if the total deposits reported under "P 02.01 - Insured and uninsured deposits" only refer to retail deposits under the Article 411.2 of CRR

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2015_2425
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 03/02/2017

C105.02 / 010 - Portfolio ID

C105.02 / 010 - Portfolio ID. Is it possible to have multiple Portfolio IDs by model?

  • 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: 2015_2424
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C105.01 / 080 - Cure rate for defaulted assets

C105.01 / 080 - Cure rate for defaulted assets. Is this only applicable to the PD models?

  • 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: 2015_2423
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C105.01 / 050 - EAD weighted average default rate for calibration

C105.01 / 050 - EAD weighted average default rate for calibration. Is the specification only relevant to the PD models themselves? Also, does this mean the PD actually used for model build, or the latest monitored position?

  • 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: 2015_2421
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Exposure class - Corporate - Specialised Lending

Does Annex I have a value of "Corporate - Specialised Lending" for exposure class?

  • 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: 2015_2418
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

C103.999 - Exposure

Is it necessary to populate the "Exposure" field 103.999 in template C103?

  • 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: 2015_2416
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Should National GAAP reporters fill in template F 18.00 and F 19.00 on non-preforming and forborne exposures?

Should National GAAP reporters fill in template F 18.00 and F 19.00 on non-preforming and forborne exposures?

  • 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: 2015_2415
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Exclusions of liabilities matched by promotional loans

According to Article 5 (1) (f) of Commission Delegated Regulation (EU) 2015/63, can exclusions of liabilities matched by promotional loans be greater than the sum of promotional loans themselves?

  • 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: 2015_2414
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 30/10/2015

Recovery rate of the foreclosure assets calculation

Regarding to the Supervisory Benchmarking Process, Annex III, C 105.01:When calculating the recovery rate of the foreclosure assets, should the recovery rate include a prediction for LGD for the recent defaults or only observed recoveries are expected? 

  • 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: 2015_2412
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Definition of portfolio 1.2

Google does not exist anymore. Alphabet Inc. was created as a subsidiary directly owned by Google Inc. The restructuring process was completed on October 2, 2015. Alphabet retains Google Inc.'s stock price history and continues to trade under Google Inc.'s former ticker symbols "GOOG" and "GOOGL". In the description of the portfolio 1.2, it is written: “Long 100 contract OTC Google (GOOG) OTM 3-months call options.” Could you please clarify if we should book on: - Alphabet Inc Class C (GOOG) - Alphabet Inc Class A (GOOGL)

  • 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: 2015_2410
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Type of Facility, Annex II - Table C103 - Column 070 (k)

Are facilities like "unissued guarantees, stand by letter of credit and warranties" as mentioned in Annex II, table C103, column 070 k) in scope of this reporting?

  • 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: 2015_2409
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Type of Facility, Annex II - Table C103 - Column 070 (g)

Could you please provide an example of what type of facilities shall be classified as "Undrawn purchase commitments for revolving purchased that are able to be unconditionally cancelled or that effectively provide for automatic cancellation at any time by the institution without prior notice" as per point g) of column 070 in table C103?

  • 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: 2015_2408
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Scope of reporting on 11.04.2016

In respect of reporting date 11.4.2016 we are supposed to report only about the details on exposures in 1cHigh Default Portfolios 1d in table C.103. Is it correct to assume that for our submissions in respect of tables C.105.1 1cDefinition of internal models 1d and C.105.2 1cMapping of internal models to portfolios 1d we would also only be required to submit information only in respect of 1cHigh default portfolios 1d, i.e. for the same portfolios as reported about in template C.103?

  • 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: 2015_2407
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission: