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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

Application of Article 215(2)(b) of the CRR

Can the competent authorities be satisfied that the effects of a guarantee (which covers losses resulting from the non-payment of interest and other types of payments which the borrower is obliged to make) justify the treatment of eligible unfunded credit protection when the time of payment such guarantee is indeterminate? Are there other considerations that the competent authorities should take into account to be satisfied with the effects of the guarantee to justify such treatment, in addition to those listed in article 213 and 215(1)(b) and (c) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2306
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 18/11/2016

Certificate of Deposits (CDs)

How should we treat CDs (Certificate of Deposits) that we have issued? Could we treat them as deposit or should they be treated the same why as an issued senior bond?

  • 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_2305
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 13/05/2016

Risk weighting under standardised approach of an exposure secured by mortgage on residential property being constructed by the borrower (self-build) during the period of construction

Where a residential property is being constructed, and the mortgage loan finances both the construction and subsequent occupation of the property, and also provided that the loan is at all times fully and completely secured by the property in its current condition, for risk weighting purposes it is subject to Article 125 (1) (a) as “residential property which is or shall be occupied or let by the owner”, further assuming it also complies with the conditions in paragraph 2 of the Article, would  the 35% risk weight apply under that Article during the construction period as well as during occupation of the completed property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2304
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Definition of retail deposits with higher outflow rate

What is the definition of the condition for retail deposit with higher outflow rate: "the rate significantly exceeds the average rate for similar retail products"? Bucketing our retail deposits we have a two-fold problem with defining when deposit rate on our product significantly exceeds or does not exceed the average rate for similar retail product.

  • 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_2303
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 27/04/2018

SREP and combined buffers

Article 104(1)(a) of the Directive 2013/36/EU (CRD) states that competent authorities have the power to require institutions to hold own funds in excess of the requirements set out in "Chapter 4 and Regulation 575/2013", i.e. in excess of the minimum capital requirements set in the CRR plus the capital buffers. Moreover, Articles 129(5), 130(5) and 131(13) of the CRD prevent the use of CET1 capital required per Article 104 to meet any of the buffer CET1 requirements.1) When the competent authorities give to an institution an individualised CET1 capital requirement (so-called SREP requirements or Pillar 1 + Pillar 2 requirements), does this include any potential combined buffer requirements, since any additional requirement per Article 104 should come on top of the requirements imposed by Chapter 4 of the CRD and by the CRR ?2) In particular, if a competent authority changes the systemic risk buffer (SRB) or the other systemically important institutions buffer (O-SIIB) applicable to a bank would this not increase the total Pillar 2 + Pillar 1 requirement of the bank, unless the new Pillar 1 requirement went above the old Pillar 1 + Pillar 2 requirement or unless the competent authority also changed the total SREP requirement of the bank?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2302
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as final Q&A: 26/08/2016

Reporting of retail deposits to internet banks that are also partly used as collateral for various broker services such as forex and other OTC derivatives.

As per Commission Delegated Regulation EU of 10.10.2014 to supplement Regulation 575/2013 with regard to liquidity coverage requirements for credit institutions, it is stated that outflows from other retail deposits should be treated according to Article 25. Does this include retail deposits that are also partly used as collateral for broker services? 

  • 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_2301
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 28/04/2016

Retained Earnings in COREP/FINREP

I kindly require some clarification regarding the Retained Earnings amount which should be reported in F01.03 r190, c010. From my understanding and as per validation rule v3467_i, {F 01.03, r190 , c010}=={F 46.00, r210 , c060}, the Retained Earnings figure which should be reported in F 01.03 should not include Profit or Loss Attributable to Owners of the Parent (eligible and non-eligible profit or loss for the year) as the latter is to be reported in F 01.03 r250, c010. Conversely, Retained Earnings reported in COREP C 01.00 r130, c010, contains Previous Years Retained Earnings (r140) and Profit or Loss Attributable to Owners of the Parent (r160). In this regard, could you please confirm, or otherwise, that F 01.03 r190, c010 should not be equal to C 01.00 r130, c010? Kindly note that no guidance is provided in the EBA FINREP instructions.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2300
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Given the legal reference reported in the Annex IV, a clarification about the annual default rate computation is required

With reference to the field "Default rate latest year" (Annex IV C 103.00, field 190) the following legal reference is reported: - C20 13 c40 of table 9.2 of Annex 1 of ITS reporting This table contains quarterly default rates. For "Default rate latest year" field, an annualized quarterly default rate is required, or a default rate directly on yearly basis can be determined?

  • 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_2297
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

A clarification about the collateral value to provide in the relevant templates is required

For the fields 080, 120 (i.e. Collateralisation status, Collateral type) of Annex II, templates 102-103, all the type of collateral are required (i.e. Eligible financial collateral, Receivables, Real estate, Physical collateral, Other funded credit protection, Credit derivatives, Guarantees). In Annex IV, templates 102-103, for the field 120 (i.e. Collateral value) the instructions refer to “market value” only. Does this mean that Guarantees do not have to be considered? In this case why the legal reference does not refer only to the columns 180-210 of table 8.1?

  • 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_2296
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

A confirmation about the legal reference reported in Annex IV is required

With reference to the field “Provisions non-performing exposures” (Annex IV 102, column 160, Annex IV 103, column 160) the following legal reference is reported: - c50 - 60 of table 9.2 of Annex 1 of ITS reporting. Given that this table does not include data for all the countries within the Group (i.e. a relevance threshold is set) and that the distinction between performing/not performing exposures is not available (only on the total value is available), we ask for a confirmation on the above mentioned legal reference.

  • 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_2295
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

How to manage different local rating scales

With reference to 1cRating 1d field (template 103 13 Annex IV, column No 50) how the different local rating scales must be treated for consolidated reporting, i.e: If a master scale is available at Group level (e.g. for Pillar III purposes), does the Institution have to adopt it, or it can choose to create an ad hoc master scale? In this latter case, if different rating scales (with different number of grades) are applied within the Group, can the Institution define the number of grades or does it have to contact its competent authority in advance to agree upon the way to define the new scale?

  • 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_2294
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification for filling the 'Not applicable' value in Annex II and IV

To clarify the meaning of the value 'Not applicable' within Annex II. In some cases the 'Not applicable' value seems to represent a total portfolio (refer to Example 1). In other case, the 'Not applicable' value seems to mean that the driver is not significant for the specific cluster of analysis (refer to Example 2). In other cases, the 'Not Applicable' value seems to be a residual value (refer to Example 3). Summarizing, does the meaning of 'Not applicable' depend, in Annex II, on the considered field or it always represent a total portfolio? For every field of Annex IV, 'Not applicable' shall be used always when none of the answers in the list is correct, therefore does it represent a residual cluster?

  • 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_2291
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

A confirmation is required about the rules to fill the EBA Benchmarking templates

Could you confirm whether the following interpretation is correct? Fields of Annex I and the relevant values define the benchmarking portfolios (i.e. the portfolio of analysis identified by the portfolio ID). The same exposure can be included in more than one portfolio_id only in case it is clearly specified in the EBA instructions (i.e. refer to Example 1). For all the other fields the values listed in Annex I have to be considered mutually exclusive (i.e. the same exposure cannot be associated to two different values, with the exception of the 'Not applicable' value). For each portfolio id, Institutions have to fill the information contained in Annex III. These information have to be aggregated in case they are defined at a lower level than the relevant portfolio id (refer to Example 2). According to Annex I (template 103) Rating is not a segmentation criteria (not applicable), but in Annex II (template 103) the internal Rating grade shall be inserted. This would mean that: - is not the portfolio_id unique and an artificial further segmentation would be created? - should the rating grade be dependent on the average PD which was calculated for that portfolio? - is the field 'Rating' indeed required also in Annex I (template 103), i.e. the 'Not applicable' value, indicated in Annex I (template 103) is not significant

  • 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_2290
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Identification of exposures treated under Standard approach

The part of transactions which is secured by guarantees could be moved to the permanent partial use, i.e. standard approach. RTS, page 34, point 10, states that: 1e [ 26] As a result, the benchmarking exercise should only relate to validated internal approaches. Institutions should not provide data for those portfolios which include instruments or risk factors that are reported under the standardized rules. 1d What exactly is meant with 1cportfolio 1d? Shall only be a part of the transaction be excluded (part which is STC), shall the customer be excluded or the portfolio of which the transaction/partner is part of?

  • 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_2288
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Reporting of individual exposures relating to a group of connected institutions for which there is a cash pooling agreement, where some creditor nostri accounts are offsetting debtor nostri balances

Our institution has a cash pooling agreement relating to three bank accounts opened in different banks belonging to the same Group, so that cash transfers are processed automatically overnight to one centralizing bank account.Up to now, in the LE2 template, we have been reporting the resulting net exposure on this group of connected counterparties and in the LE3 template, the detail for each of the three counterparties, but we have been encountering the following validation rule blocking errors: v0648_m, v0649_m,  v3799_s and v3802_s. These errors are due to the input of a negative outstanding for one of the banking counterparts, corresponding to a creditor nostro balance.Our question is how to fill in the LE3 template in this situation ?

  • 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_2286
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/08/2017

C 22.00 (Market Risk FX) - Scope of Memorandum Items

Please clarify whether the Memorandum Items on COREP template C 22.00 (Market Risk FX) which are to be reported on rows 130 and below should include all of an institution's gross and net FX positions, regardless of the approach used for capital requirements of these positions. Please also clarify whether these items should be reported by all institutions with the relevant COREP reporting requirement, or only by those institutions which meet (i.e. exceed) the 'de minimis' threshold defined in Article 351 CRR.

  • 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_2285
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

FinRep Table 2: Interest income & Expense: Derivatives – Hedge accounting, interest rate risk

How should interest income & interest expense on derivatives (hedge accounting) be presented in Table 2 ? (i) Linked basis: Reported in Interest Income (row 070) if the derivative is hedging an asset item and Reported in Interest Expense (row 130) if the derivative is hedging a liablity item OR (ii) Gross basis: Hedge accounting derivatives resulting in Interest Income should be reported in row 070 and hedge accounting derivatives resulting in Interest Expense should be reported in row 130.

  • 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_2284
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Application of the even deduction rule in case of intragroup transactions booked - by institutions which are parties to the contract - in different amounts

How to apply the even deduction rule stipulated in the Article 5(2) of the Commission Delegated Regulation (EU) 2015/63 and further clarified by the EBA Q&A 2015_1893 (Treatment of specific liabilities - even deduction) in cases where each party books the transaction in different amount?

  • 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_2283
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 05/08/2016

Completion of Annex I, Template C103.00 of the ITS needed?

For the high default portfolio benchmarking exercise we have noted that Annex I, Template C103 of the ITS is not included in the "DPM Table Layout and Data Point Categorisation 2.3.1.zip" for benchmarking on the EBA’s website: https://www.eba.europa.eu/-/eba-publishes-updated-dpm-and-xbrl-taxonomy-... Article 2(1)(c) of the “EBA Final Draft Regulatory Technical Standards on benchmarking portfolio assessment standards and assessment sharing procedures under Article 78 of Directive 2013/36/EU” refers to this template, but does not state that the template needs to be completed. Is completion of the Template C103 from Annex I required for the April 2016 benchmarking submission?

  • 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_2282
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Clarification regarding the reference year for the purpose of the remuneration data to be collected by Competent authorities

The guidelines specify that data reported should relate to remuneration awarded to staff for the performance year preceding the year in which the information is submitted. To which amounts and year does the guideline refer exactly with regard to the collection of the fixed and variable component of remuneration?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/07 - Guidelines on data collection exercise regarding high earners
  • ID: 2015_2276
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 15/01/2016