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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

Allocation of the collective impairment allowances

In order to fill in the FINREP templates, how should be performed the allocation of the collective impairment allowances among group assets?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Financial assets impairment

Where should be reported in the financial reporting forms F 04.04 and F 07.00 the allowances related to individually insignificant financial assets which were not assessed for impairment on individual basis (following the option of IAS 39.64), but were found collectively impaired?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Financial assets impairment

Considering the provisions of para.37 from Part 2 of Annex V to the ITS (FINREP instructions), are there any IFRS provisions allowing entities to perform the computation of the impairment losses at the portfolio level for individually insignificant financial assets found to be impaired on individual basis?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Financial assets impairment

Do impaired financial assets also include the ones that are found to be impaired at the group level or only those individually impaired? More specific, in the financial reporting form F 04.04, the column 020 “Impaired assets [gross carrying amount]” includes only the financial assets impaired on individual basis (with specific allowances for individually assessed financial assets or specific allowances for collectively assessed financial assets)?

  • 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)

Level of application of the new FINREP framework

Can a competent authority impose FINREP at a solo level. Moreover, would a competent authority be free to add to or delete information from a specific template?

  • 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)

Scope of application of the new FINREP framework

Are the credit institutions that should not prepare consolidated accounts according to the prudential rules under the scope of the new FINREP framework?

  • 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)

FINREP: F07.00 reporting of past due assets

How to split past due not impaired financial assets according to the number of days past due? According to the Instructions in Part 2, paragraph 48: “Assets qualify as past due when a counterparty has failed to make a payment when contractually due”. Q1: Will the whole asset/loan be qualified as past due or only its part, for which the counterparty failed to make a payment? According to the Instructions in Part 2, paragraph 48 : “The amounts of such assets shall be reported and broken down according to the number of days past due”. Q2: Should the individual financial asset/loan be split into parts according to the “age” of individual instalments or should the financial asset/loan be reported in the col. for the “oldest” past due instalment? In this case “to split” will be relevant to financial assets portfolio (= individual asset will be kept as a whole, but portfolio will be split) .

  • 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)

Correct consideration of the saving accounts in the LCR calculation of outflows following Article 421 (5) of Regulation (EU) No 575/2013 (CRR)

Is it correct that German “Savings Accounts” are to be considered in the LCR calculation only up to the threshold of EUR 2000,- penalty-free withdrawals per account?

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

Definition of the words "on group basis"

What is the definition of the words “on a group basis” in Article 411 (2) of Regulation (EU) No 575/2013 (CRR)

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

Consideration from residual values in the LCR calculation

As significant inflows from residual values of large portfolios of leased cars are not regulated within Part 6 of Regulation (EU) No 575/2013 (CRR) how may institutions who professionally manage such portfolios take those values into account?

  • 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

Notifications of agents and subagents of credit institutions in the European Economic Area (EEA)

1) Is it allowed for a credit institution to provide money remittance services via agent cross-border in the EEA? 2) Do agents have to be notified to the home-/host authority and if so under which directive? 3) Do agents have to be notified by way of freedom of establishment or by way of freedom to provide services? 4) Are agents to be treated as branches? 5) Is it allowed for an agent of a credit institution which provides money remittance services cross-border in the EEA to use subagents? If yes: a) Does a sub-agent have to be notified? b) On which legal basis? c) To which Authority? d) Does the credit institution or the agent provide notification and, if so, freedom of establishment or by way of freedom to provide services?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Outflows associated with shorts - net or gross

Can you clarify whether Article 423(4) of Regulation (EU) No 575/2013 (CRR) requires firms to: 1) assess long and short positions gross per ISIN and to treat shorts gross by ISIN, reporting an outflow under Article 423(4) corresponding to the sum of all the gross short positions per ISIN (not covered >30 days); or 2) assess shorts net of any longs currently used to cover shorts via stock collateralised stock borrow e.g. a long in one ISIN (not qualifying as liquid assets per Article 416) that is currently used as collateral to cover a short in another ISIN (stock collateralised stock borrowing) and maturing inside 30 days, can continue to be eligible as collateral to cover shorts thus reducing the outflow reported under Article 423 (4).

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

Leverage Ratio: C45.00 (LRCalc) r010: SFTs exposure according to CRR 220

The exposure for repurchase transactions, securities or commodities lending or borrowing transactions, long settlement transactions and margin lending transactions should be calculated in accordance with Article 220 (1) to (3). Should the volatility adjustments be taken into account for the determination of the leverage ratio exposure value of exposures subject to Article 220?

  • 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)

Firm shorts covered by client longs

We assume that an outflow should be reflected under Article 423 (4) of Regulation (EU) No 575/2013 (CRR) for any firm short currently covered using a client long position, unless the residual term of the borrowing of the client stock used to cover the short is contractually committed beyond 30 days.

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

FINREP: Counterparty breakdown - hospitals, schools, social secretaries

As what counterparty shall hospitals, schools and social secretaries be reported? Are there any thresholds (e.g. turnover) which when exceeded then the entity shall be reported as different counterparty (e.g. in current FINREP hospitals are treated households, when turnover exceed the limit then the hospital is reported as corporate)?

  • 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)

NSFR: Calculation of liablities and receivables from derivatives if there is no netting agreement

NSFR: How should the amount of liablities and receivables from derivatives be calculated if there is no netting agreement with the counterparty?

  • 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)

Own funds deduction (granted subordinated loan)

According to Directive 2006/48/EC regarding own funds deduction, a subordinated loan granted by institution ‘A’ to institution ‘B’ in which institution ‘A’ has a significant investments has to be deducted from institution ‘A’s own funds (in 50% from Tier1 and in 50% from Tier2). Simultaneously a received subordinated loan is treated as component of Tier2 of institution ‘B’. In Regulation (EU) No. 575/2013 (CRR) there is no clear information regarding deducting such an instrument from own funds. In the light of the above, should a granted subordinated loan be treated as Tier2 deduction - according to the Article 66 of CRR? If not, how should such an instrument be treated?

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

FINREP: F1.1. row 040 "other demand deposits"

On the basis of the validation rules of template F1.1, row 040 is part of the sum of row 010 'cash and cash balances at central banks'. So one can assume that row 040 'other demand deposits' are deposits with central banks. However, the guidance in annex V part 2.3 (1.1 assets - § 3) stipulates that 'other demand deposits' includes balances receivable on demand with credit institutions. This seems contradictory to us. Please can you confirm whether row 040 of template F1.1, comprises 'other demand deposits' with central banks or with credit institutions.

  • 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)

FINREP: Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net

During the last update on the ITS Annex III in July 2013 the FINREP P&L template was modified by removing the line item for "Gains or (-) losses on derecognition of investments in subsidiaries, joint ventures and associates, net" (table 2 row 320 ITSoR March 2013) without any explanation. But in comparison with the published DPM in July 2013 which still contains the line item there is an inconsistency. In our opinion the line item is required to reach a consistent and meaningful P&L Statement, so that we assume that removing the line item is a mistake in the templates. If it is not an error it is necessary to give guidance on the disclosure of gains or losses on derecognition of investments in subsidiaries, joint ventures and associates.

  • 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)

Interaction between Qualified CCPs and Reporting

Institutions must meet higher capital requirements as long as CCPs are not qualified. Most of the Clearing organisations are working for many years on the derivative market. Will EBA (or national competent authorities) create an interim agreement for that special issue? CCPs are already supervised by their national financial authorities.

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