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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

Pillar 3 Disclosure: Template EU CQ1: Credit quality of forborne exposures (Col e & f; R090 Loan commitments given ) - Clarification on Mapping Logic

According to the EBA mapping: (Col e & f ; R0090) for row “Loan commitments given” under impairment section are mapped to template F19, which is presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CQ1. Please confirm whether this interpretation is correct. 

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

Pillar 3 Disclosure: Template EU CR1: Performing and non-performing exposures and related provisions (Column g-l; R150-210 Off balance sheet exposure) - Clarification on Mapping Logic

According to the EBA mapping, columns g to l (rows R150–R210) for off-balance sheet exposures are mapped to template F18, which would be presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CR1. Please confirm whether this interpretation is correct.  

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

Credit institutions should not consider as outsourcing

Within Title II, Section 3, Recital 28 Guidelines on outsourcing an exemption what should not be considered an outsourcing is given. Under this exemption can we consider that purchases of goods e.g., standard software or hardware without customization or integration into critical processes, are not outsourcing? For example if the SaaS application is used solely for non-critical, non-banking functions (e.g., HR training platforms, marketing tools), and does not impact the institution’s operational resilience or critical functions, can it be treated from a bank perspective as purchase of goods that fall outside the EBA guidelines on outsourcing arrangements scope?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/02 - Guidelines on outsourcing arrangements

Clarification on Q&A 2024_7073: Treatment of two-leg derivatives with respect to rate type and currency

Example 1: Fixed IR asset changed to floating with an IRS – IRS floating receiver and fixed payer - Representation in J 05.00, J 06.00 and J 07.00   Let us consider a scenario where the fixed rate asset (hedged item) is a mortgage loan that perfectly matches, in terms of notional amount and financial characteristics, the receive leg of an interest rate swap (IRS).  According to the Q&A:  For the receive leg, the notional amount must be reported in column 0260, under rows 0140 to 0170. The weighted average yield should be reported with a positive sign in column 0300, and the corresponding repricing cash flows should be reported with a positive sign in columns 0320 to 0390, all under rows 0140 to 0170.  For the payer leg, the notional amount should not be reported. The weighted average yield must be reported with a negative sign in column 0050, and the associated repricing cash flows must be reported with a negative sign in columns 0070 to 0250, again under rows 0140 to 0170.  Could you please clarify how potential asymmetries should be addressed in cases where the notional amount of the payer leg of the IRS is not reported, which may lead to both the fixed rate exposure of the hedged item and the floating rate leg of the hedging derivative being simultaneously recognized, potentially distorting the risk exposure at the total assets level? Example 2: Floating IR liability changed to fixed with an IRS – IRS floating receiver and fixed payer - Representation in J 05.00, J 06.00 and J 07.00  Let us consider a scenario where the floating rate liability (hedged item) is a debt security that perfectly matches, in terms of notional amount and financial characteristics, the receive leg of an interest rate swap (IRS).  According to Q&A:  For the receive leg, the notional amount must be reported with a positive sign in column 0260, under rows 0140 to 0170. The weighted average yield should be reported with a negative sign in column 0300, and the corresponding repricing cash flows should be reported with a negative sign in columns 0320 to 0390, all under rows 0140 to 0170.  For the payer leg, the notional amount should not be reported. The weighted average yield must be reported with a positive sign in column 0050, and the associated repricing cash flows must be reported with a positive sign in columns 0070 to 0250, again under rows 0140 to 0170.  Could you advise on how institutions should address potential asymmetries arising in cases where the notional amount of the receive leg of the IRS is reported with a positive sign, while the notional of the payer leg is not reported (i.e., reported as zero), potentially resulting in the simultaneous recognition of both the floating rate exposure of the hedged item and the floating leg of the hedging derivative?  Example 3: Other Interest rate derivatives not designed as accounting hedges – IRS floating receiver and fixed payer - Representation in J 05.00, J 06.00 and J 07.00   Could you provide guidance on how institutions should address potential asymmetries arising in cases where only the receiver leg of an IRS transaction is reported, potentially resulting in an incomplete representation of the associated risk exposure? Example 4: Fixed USD asset changed to fixed EUR with a CCS USD fixed payer / against fixed EUR receiver - Representation in J 05.00, J 06.00 and J 07.00    In this example, we report the same observations as in Example 1, considering the fixed exposure represented in EUR and USD templates.  In addition, we would appreciate confirmation regarding the appropriate representation of the average yield. Specifically, should the yield of the payer fixed USD leg be reported under template J 05.00 in EUR, as indicated in the official Q&A, or under J 05.00 in USD?

  • 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 (repealed)

factor to apply to non performing exposures to which a risk weight is 0% in a performing situation for the purpose of calculating the amount of unsufficient coverage

is it possible to consider that the derogation applied to the part of the non-performing exposure guaranteed or counter-guaranteed by an eligible protection provider referred to in Article 201(1), points (a) to (e), the unsecured exposures to which would be assigned a risk weight of 0 % under Part Three, also applies to unsecured exposures themselves when assigned a risk weight of 0% ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/06 - Guidelines on management of non-performing and forborne exposures

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

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

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

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

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

EBA Mapping Tool Clarification - EU LIQ2

The EBA Mapping Tool logic in relation to EU LIQ2 does not appear to capture the 'Weighted Value' component. The current logic is as follows: {C 81.00, r0150, c0100} + {C 81.00, r0280, c0100}

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

Discretionary pension benefits

According to Section 151 of the EBA Guidelines on sound remuneration policies under CRD (EBA/GL/2021/04) (“EBA Guidelines”), pension benefits that are not performance-based and are consistently granted to a category of staff as part of the company’s pension scheme should be regarded as routine employment packages. How should the concept of a “company’s pension scheme,” as referred to in Section 151 of the EBA Guidelines, be interpreted? For instance, can an established and consistently applied long-term practice qualify as a pension scheme, even in the absence of a formal written policy or documented scheme? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)

Discretionary pension benefits

According to Section 151 of the EBA Guidelines on sound remuneration policies under CRD, EBA/GL/2021/04 (“EBA Guidelines”), pension benefits included in the company’s pension scheme that are not based on performance and that are consistently granted to a category of staff should be considered as part of routine employment packages.  What is the minimum number of persons that can form a category of staff in the meaning of the aforementioned Section? For example, can the Chief Executive Officer and Deputy Chief Executive Officer of an institution together (i.e. two persons) be considered “a category of staff” in the meaning of Section 151 of the EBA Guidelines? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)

Discretionary pension benefits

Proportionate regular pension contributions on top of the mandatory regime are cited as an example of routine employment packages in the definitions section of the EBA Guidelines on sound remuneration policies under CRD (EBA/GL/2021/04) (“EBA Guidelines”). How large may such annual pension contributions be — whether in monetary terms or as a percentage of the staff member’s total annual remuneration — for the benefit to be considered proportionate and, provided that other criteria are met, qualify as a routine employment package (and therefore as fixed remuneration)? Does the size or other characteristics of the institution influence the assessment of whether a pension benefit is proportionate or routine? More broadly, what factors typically affect this assessment — for instance, do national industry-level remuneration benchmarks or the remuneration level within a specific institution play a role?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)

EBA Mapping Tool Clarification - EU CR5

For last Column aa – the mapping prescribed by EBA is ‘col z - {C 07.00, sum of rows [from 140 to 280], c 230, s0002}’ which means: •    Col z (i.e. sum of all the exposure value under different RW) •    C7:o    sum of rows [from 140 to 280] = sum of all RW% o    C230 in C7 = which ‘RISK WEIGHTED EXPOSURE AMOUNT OF WHICH:  WITH A CREDIT ASSESSMENT BY A NOMINATED ECAI’  Our question is why we use exposure value minus RWA with a ECAI assessment? 

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

EBA Mapping Tool Clarification - EU CQ4

We believe that the mapping logic applied to EU CQ4 is incorrect for the following: For EU CQ4, r010, col a - Mapping is "'{F 20.04, sum(r0080, r0140), c0010} - {F20.04, sum(r0080, r0140), c0011}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col b - Mapping is "{F 20.04, sum(r0080, r0140), c0025}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col c - Mapping is "'{F 20.04, sum(r0080, r0140), c0026}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col d - Mapping is "{F 20.04, sum(r0080, r0140), c0012}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col e - Mapping is "{F 20.04, sum(r0080, r0140), c0031}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col g - Mapping is "{F 20.04, sum(r0080, r0140), c0040}", however, F20.04, r010,r040, r0075 are excluded

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

EBA Mapping Tool Clarification - EU CMS1 (2)

For CCR (Row2) within CMS1 - how would we capture SA IMM for S-TREA?  As the mapping in Column d/ EUd only capture S-TREA under IRB approach but nothing for exposure with SA IMM (which is also needed to recalculate to S-TREA).

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