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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

Reporting of significant currencies (> 5%) according to Article 415 (2) (a) CRR

Article 415 (2) (a) CRR says: 2. An institution shall report separately to the competent authorities the items referred to in the implementing technical standards referred to in paragraph 3 or 3a of this Article, in Title III until such time as the reporting obligation and the reporting format for the net stable funding ratio set out in Title IV have been specified and introduced in Union law, in Title IV and in the delegated act referred to in Article 460(1), as appropriate, in accordance with the following: (a) where items are denominated in a currency other than the reporting currency and the institution has aggregate liabilities denominated in such a currency which amount to or exceed 5 % of the institution's or the single liquidity sub-group's total liabilities, excluding own funds and off-balance-sheet items, reporting shall be done in the currency of denomination; (b) where items are denominated in the currency of a host Member State where the institution has a significant branch as referred to in Article 51 of Directive 2013/36/EU and that host Member State uses another currency than the reporting currency, the reporting shall be done in the currency of the Member State in which the significant branch is located; (c) where items are denominated in the reporting currency, and the aggregate amount of liabilities in other currencies than the reporting currency amounts to or exceeds 5 % of the institution's or the single liquidity subgroup's total liabilities, excluding own funds and off-balance-sheet items, the reporting shall be done in the reporting currency. There has to be breakdown by currencies if the 5% condition is met. ITS article 4 sets the reporting thresholds for entry and exit criteria. Does this means that if the 'significant currency' conditions is not met anymore then exit criteria 'three consecutive reporting reference dates' has to be followed? Or institution can stop reporting other currencies as soon as ratio is < 5%?  

  • 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
  • ID: 2023_6799
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 14/09/2023

Use of the last available data for risk quantification sample

Given the requirements of Articles 179(1)(a) and 175(4)(b) CRR, in case of a model development, should the last available one-year snapshot be used for risk quantification purposes (i.e., for the computation of the long-run average default rate) or be set aside for out-of-time validation tests?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2023_6798
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 02/02/2024

Other assets/liabilities in the context of NSFR templates (C 80.00 and C 81.00)

Should institutions report as Other Assets or Other Liabilities also the IFRS accounting corrections deriving from the adoption of a macro-hedging strategy on Interest Rate Risk? 

  • 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
  • ID: 2023_6797
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Other assets/liabilities in the context of NSFR templates (C 80.00 and C 81.00)

Should institutions report as Other Assets or Other Liabilities also the IFRS accounting corrections deriving from the adoption of a macro-hedging strategy on Interest Rate Risk?  

  • 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
  • ID: 2023_6796
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 14/09/2023

EBA VR Taxo v3.2.1, Validation rule v11909_m to v11961_m; and v7820_m; v7821_m

Why there is still some validation rules which control if Financial Garantee and Collateral are less than the Gross Carrying Amount in FINREP 18?

  • 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
  • ID: 2023_6795
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 07/06/2023

Consideration of default dependencies for MoC C quantification

Do financial institutions have to incorporate the variability of the macro-economic factor (of the Vasicek model) into the quantification of the MoC C? In other words, do financial institutions have to incorporate default dependencies between obligors into the MoC C quantification?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2023_6794
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/01/2024

Capital instruments eligible as Tier 2 Capital

Under the CRR, capital instruments and subordinated loans shall only qualify as Tier 2 instruments provided that the conditions outlined in Article 63 are met. This includes the condition that “the instruments are directly issued by an institution and fully paid up” as per Article 63(a). As further outlined in Annex II instruction to row 0771, such capital instruments also include subordinated loans insofar that they fulfil the eligibility criteria. We would like to request clarification on the eligibility criteria of Article 63(a) in the context of an amendment in the regulation’s text of Article 64, effected via CRR II (Regulation 2019/876). This clarification is sought with the aim of determining whether the “accrued interest” on subordinated debt may be eligible for inclusion as Tier 2 capital, having regard to Article 63(a) and Article 64 in particular.

  • 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
  • ID: 2023_6793
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Boundary between the banking book and the trading book

A bond issued that has an automatic early redemption option linked to an equity index can be treated as follows: - the market value net of the embedded option related to early redemption is included in the banking book; - the option related to early redemption is unbundled and placed in the trading book so that all risks participate in the market risk requirement? In the case of not being able to unbundle the option related to early redemption and thus placing the equity risk in the trading book, should the institution move the entire bond within the trading book? Or does the bond remain in the banking book and can the early redemption risk from the equity index be managed in the banking book?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6792
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 30/05/2023

Permission to reduce own funds or eligible liabilities and deduction rules in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument)

Should deductions from own funds and eligible liabilities with regards to a permission to reduce own funds or eligible liabilities in accordance with Article 77 of Regulation (EU) No 575/2013 (CRR) in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument), rather than upon the exercise of a call option,  be made right after the permission from the competent authority / resolution authority is granted or could it be later at the time of the institution’s public announcement of the liability management exercise in accordance with Article 28(2) of the RTS on Own Funds? In that context, how should the concept of ‘sufficient certainty’ of Article 28(2) RTS be applied?

  • 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
  • ID: 2023_6791
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/09/2023

Multi-licensed entity capital requirement

Whether a payment institution that also has a crowdfunding license must meet the capital requirements of both authorizations in aggregate?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6790
  • Topic: Authorisation and registration
  • Date of submission:

Reporting of marginal deposit facility amounts (overnight deposits with the central bank) in templates C72 and C74.

It is not clear how the amounts in Central Banks regarding the marginal deposit facility should be treated in the calculation of the LCR and reported in C72 and C74.

  • 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: 2023_6789
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 15/02/2024

Fraud reporting

How we should treat the transactions that are initiated by PSP (for example refunds, chargebacks, etc.), but those transactions are related to cardholder's actions.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
  • ID: 2023_6788
  • Topic: Fraud reporting
  • Date of submission:

Assessing the level of concentration, measures and indicators

What is EBA's opinion regarding the inclusion or not in the determination of the Herfindahl-Hirschman Index (used for determining additional capital in case of credit risk concentration) of the exposures for which the RWA is zero (zero capital allocation) ?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/03 - Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) and supervisory stress testing under Directive 2013/36/EU
  • ID: 2023_6787
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as Rejected Q&A: 30/05/2023

Explanation regarding the term "non-reducible"

Could you please explain what does mean the term "nonreducible" in the context of life insurance policy pledged to a lending institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6786
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/07/2023

Algorithm to calculate the TOP Institution (resp. Shadow Banking) te report in C27 of Large Exposure Report

How to calculate the TOP 10 Institutions (resp. Shadow Banking) for GCC? Should be have to consider the exposure at countrepart level or consolidated level?

  • 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
  • ID: 2023_6785
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 29/06/2023

Reporting of deposit facility (overnight deposits with the central bank) in template C_66.01

It is not clear in which row of template C_66.01 the overnight deposits in central banks such as the deposit facility shall be reported.

  • 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
  • ID: 2023_6784
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 15/05/2023

C_81.00 ASF from capital items and instruments - Tier 2

It is written in article 428i (CRR2) that 'the amount of available stable funding shall be calculated by multiplying  the accounting value of various categories or types of liabilities and own funds by the available stable funding factors'. Concrete example: please give us the answer If credit institution has on balance sheet under Liabilities: (residual maturity for part of debt securities is more than 1 year and less than 5 years (2 000 000 eur) and other part has residual maturity more than 5 years) 1. Debt securities issued - 10 200 00 eur           1.1 Debt certificates - 10 000 000 eur           1.2 Interests payables on debt certificates - 200 000 eur   What amounts should be reported on NSFR C81.00 on row 0050, column 0030 - should it be 10 200 000 euros? Or amount is without interest - 10 000 000 euros? Or should it be equal to C01.00 row 0771 (where amortization is used for those debt securities that have residual maturity less than 5 years)? Also checked th Question: 2021_6016 - it does not give the aswer about the interests payables - should they be included or not?  

  • 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
  • ID: 2023_6783
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Securities lent under sale accounting (C40 and C43 treatment)

As per Q&A 6093, clarification has been provided on the disclosure treatment of securities lent in a repurchase transaction that are derecognized due to sales accounting transactions under the applicable accounting framework. The Q&A appears to state that institutions shall reverse all sales-related accounting entries and these securities are to be treated as SFTs in both C40 (row 071) and C43 (row 040 or 060) disclosure. Under sale accounting treatment, the requirement is to reverse the sale treatment and therefore the securities will be reported in its original form, which is expected to be trading portfolio assets. Given this, is the correct treatment not for securities to be reported in C40 (row 090) and C43 (row 070) respectively?

  • 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
  • ID: 2023_6782
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/09/2023

ESG P3 - Template 7 Decision tree KPI GAR for Households

In which row/group of rows from template 7 should be disclosed Households not included in the of which populated on the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6780
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023