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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.

List of Q&A's

Definition of Net defined benefit assets [Carrying amount] in F44.01

Please can we clarify what is required in row 0090 of FINREP template F44.01 in terms of the "Net defined benefit assets" ? i.e. should this row only include surplus amounts that shall be recognised in the balance sheet given that the previous sign validation rule v3985_s has now been deactivated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

EBA Funding Plan return - Annex 1 - 2.3.1 (P01.02) and 9.1 (P05.00)

Guidance is needed on why there is a specific AT1 issuance/maturity section under debt securities/liabilities in P01.02,r191,c010 & P05.00, r0030 & r0040, c10-40 whereas under IFRS and therefore FINREP they are included in equity. This is leading to a validation error with FINREP which we would like the EBA to consider on the most appropriate way to resolve for the completion of the Funding Plan return.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/05 – Guidelines on harmonised definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2 - repealing EBA/GL/2014/04

Pillar 3 Disclosure - EU OV1 – Row 1 ‘Credit risk (excluding CCR)’ mapping clarification

In Template EU OV1, Row 1 "Credit Risk (excluding CCR)", we observe that the current mapping includes the following components from C 02.00: {C 02.00, r0690, c0010} – Other risk exposure amounts minus {C 02.00, r0720, c0010} – Requirements for large exposures minus {C 02.00, r0755, c0010} – Additional RWEA for market risk imposed by supervisor (Art. 110) minus {C 02.00, r0770, c0010} – Additional RWEA for market risk minus {C 02.00, r0780, c0010} – Transitional RWEA for crypto assets (Art. 501d(2))   While this mapping appears to isolate the portion of "Other RWA" not related to market risk, large exposures, or crypto assets, our understanding is that the total reported in row 0690 may still include other risk exposure amounts arising from non-credit risk categories, such as CCR (e.g. RWA induced by IMM PMA). Given that Row 1 of EU OV1 is intended to reflect credit risk excluding CCR, we would like to confirm whether including the residual amount from r0690 (after the above deductions) is appropriate, or if this could lead to misclassification of non-credit risk RWA under credit risk.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Instructions to follow regarding new EBA Resolution Reporting

For the sake of clarity, the Bank reports below an example for the “Value of positions on proprietary and client accounts” of the difference between the two instructions 1.      SRB Guidance on FMIR: […] Daily average value at end of settlement day over the previous year. If not available, daily average value over a shorter time period and c0140 and c0150 should be filled. To calculate daily averages, please use the opening days of reported FMIs. If not available, you may use the TARGET2 opening days as a proxy. Total values should be included, not only values of relevant currencies as reported in c0120-c0170 2.      EBA Instructions on New Resolution Reporting – Z09.03: […] Average value at end of settlement day over the previous year.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Structural Differences Between Annotated Table Layout and Taxonomy in GSIIDISPILLAR3 under DPM 4.1

Which representation (annotated table or taxonomy/XBRL) should be considered authoritative for defining the expected scope of data points for reporting? Should institutions follow the taxonomy-enabled structure and report values in cells that are greyed out in the annotated table, as shown in the sample XBRL file?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)

Validation rules taxonomy V4.0 C_17.01

The formulae v23510_h seems not relevant

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rules taxonomy V4.0 C_17.01

The formula of control v23509_h seems not relevant

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Justification to consider a ‘significant penalty’ and to be excluded from the outflows

Pursuant to article 25(4)(b) of Delegated Regulation (EU) 2015/61, does the cumulative loss of accrued interest, representing more than 50% of the total contractual interest income upon early withdrawal of term deposits (specifically those which have been active for more than 50% of their contractual term, have an original maturity longer than 30 days, and a residual maturity exceeding 30 days), constitute sufficient justification to consider this as a ‘significant penalty’ under article 25(4)paragraph (b), with the purpose of discouraging early withdrawal, and therefore allow such retail deposits (for which more  than 50% of contractual term has passed)  to be excluded from the outflows?

  • 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

Guidance for credit institutions on which countries fall under scope of the Critical Function Report (CFR)

We currently do not see any indication for country-specific information. Will the EBA provide requirements on which countries are to be covered for each Critical Function Report?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Clarification on column a) "Total exposures", CR7-A Template

Could you please confirm that the coloumn a) "Total exposures" of CR7-A template should be filled with outstanding amount post application of credit conversion factor without taking into account any substitution effects due to the existence of a guarantee  in accordance with Articles 166 to 167 CRR, in case the exposure covered by only unfunded credit protection (guarantees)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR

EBA Mapping Tool Clarification - EU MR3

Template EU MR3 - IMA values for trading portfolios (Row 4/8/12/16) According to the disclosure instruction (Annex XXX) & Article 455, MR3 will need to include related Internal Model Market Risk elements.  However, according to the EBA defined mapping for the above rows, which is mapped to C24.00, some IM elements (e.g. RNIME number) will be missed from the disclosure  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Application of the SME definition in specific cases

How shall the SME definition in Article 5(9) of Regulation (EU) No 575/2013 (CRR) be applied in the following cases: 1. The entity is considered both in accounts on the consolidated basis of a group and also in accounts on a “sub-consolidated” basis only considering a sub-group of this group. 2. The entity is a single entity that prepares accounts on its individual basis but is not considered in any accounts for a “consolidated situation” of a group.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Exposures to EU exchanges

Should exposures to EU exchanges be treated as exposures to institutions, under articles 119, 120 and 121?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Loans collateralized by immovable property in F 05.01 and F 13.01

Do loans collateralized by immovable property in templates FINREP 05.01 and FINREP 13.01 need to comply with Articles 124 - 126 of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Treatment of Subscription Agreements in CIUs as Off-Balance Sheet Item

Clarification is sought on the prudential treatment of subscription agreements entered into for the acquisition of units in Collective Investment Undertakings (CIUs), specifically in the context of off-balance sheet exposures under Article 111(4) of the Capital Requirements Regulation (CRR). More specifically, clarification is sought on the treatment of subscription agreements upon signing of the relevant documentation but which effects, at the time of signing, is subject to the verification of conditions precedent (these conditions normally being out of the control of the subscriber) such as the relevant fund reaching a certain size.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C 66.01 Contractual Maturity Ladder: Eligibility of retained covered bonds issued and received by other members of the same group as counterbalancing capacity

Can a credit institution include in its initial stock of counterbalancing capacity in the C 66.01 contractual maturity ladder central bank-eligible covered bonds that constitute retained own issuances from another member of the same group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Computation of the operational risk valuation adjustment after entry into force of Regulation - EU - 2024/1623

To comply with article 105, point (10) of CRR, and with article 17 of the Delegated Regulation  2016/101 we ask the following two questions:  Does the calculation of own funds requirements for operational risk in accordance with Title III of Part Three of CRR include operational risk relating to valuation processes? If the answer to the question above is yes, does the Delegated Regulation 2016/101 allow to avoid double counting of operational risk relating to valuation processes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR

Credit Conversion Factor Treatment - Loan Participation Agreements in Unconditionally Cancellable Facilities

For loan participation arrangements where Bank A (the issuing bank) originates loans classified as unconditionally cancellable and applies 0% Credit Conversion Factor (CCF) under CRR Article 111, what is the appropriate CCF treatment for Bank B as the participating bank?Specifically, should Bank B apply:- a 0% CCF - consistent with the unconditionally cancellable nature of the underlying loans issued by Bank A- Standard CCF rates (20% or higher) - based on the participation agreement structure, where Bank B cannot directly exercise the unconditional cancellation rights?

  • 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

EBA Mapping Tool Clarification - EU OV1 & EU CMS1

With regards to the mapping logic used for EU OV1 & EU CMS1, in particularly for the Market Risk related rows, these currently reference the new FRTB related reporting templates with the C 90 series. As the implementation of FRTB is set to be delayed by a further year (refer to communication from the European Commission) until 1st January 2027, we believe that the mapping logic should be updated to reflect, referencing back to the pre-CRR3 Market Risk templates C18.00-C24.00, in addition to C02.00. In addition, we feel that in relation to EU OV1 template, the rows associated to Market Risk may require amendment to reflect the pre-CRR3 breakdown, unless the interim requirement is to mirror the approach to the of reporting (in C02.00), where data is reported under the Simplified standardised approach (S-SA) only.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

fully and completely secured by mortgages for the purpose of the deduction of non performing exposures

In the context of the CRR3 and the application of the deduction of non-performing exposure from Common Equity Tier 1 as per article 47c, we would like to clarify the requirements of “ fully and completely secured by mortgages” in order to determine the "secured part of a non-performing exposure".

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable