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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

Template C 69.00 - Prices for the Various Lenghts of Funding - follow-up to Q&As 2015_1901 and 2015_2204

We note response given to question 2015_1901. Can we clarify if the treatment advised for retail current accounts also applies to cash operating accounts used by corporate entities?We note response given to question 2015_2204, could we request a definition of ‘new transactions entered into during the period’ in the case of cash accounts for the purpose of calculating the total volume reported. Is that treatment consistent to both retail and corporate cash accounts?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2016_2761
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

NSFR - Definition of Other Equity Instruments

How are Other Equity Instruments defined? Are Investment Funds (OGAW and AIF) considered as Other Equity and therefore reported in lines 720 to 770 of the NSFR? If not, in which line are Investment funds to be reported if they dont qualify as liquid 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2016_2760
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Reported overshootings in C 24.00

How should the number of overshootings in VaR be reported in C 24.00?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2016_2759
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

VaR Multipliers

How should the figures in VaR and SVaR multiplication factors be reported in C 24.00?

  • 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: 2016_2758
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Calculation of the threshold for using the simplified approach for the determination of AVAs.

Exactly matching, offsetting fair-valued assets and liabilities shall be excluded from the calculation of the threshold for the simplified approach in the determination of AVAs. Does “exactly matching” refer to specific conditions regarding the counterparties of assets and liabilities that otherwise may qualify to be offset?

  • 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
  • ID: 2016_2756
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Definition of mortgage loan and its collateral in FINREP template 13 (F13.01)

1. What kind of loans should be reported as “Mortgage Loans” for the purposes of FINREP template F13.01? 2. What kind of commercial and residential property should be reported as collateral for “Mortgage Loans” for the purposes of template F13.01?

  • 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: 2016_2754
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Clarification on the treatment of regular clearing positions of central counterparties (CCPs) in the leverage ratio exposure measure (provided CCPs are subject to leverage ratio regulation)

Can you confirm that positions which arise from a CCP’s primary clearing activity and which are already covered by EMIR-compliant risk management tools are to be excluded from the LR exposure measure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2016_2750
  • Topic: Leverage ratio
  • Date of submission:

Reporting of individuals/households names in template C 67.00

Should the individuals/households names to be disclosed when filling template C 67.00?

  • 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: 2016_2743
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

The treatment of Physical Stock balances

The ITS states firms should report the name of the top ten issuers/counterparties of unencumbered assets or undrawn committed liquidity lines granted to the institution shall be recorded in column 010 in a descending fashion.-       If a firm holds gold or other commodity stocks, does column 010 (counterparty name) need to be populated?-       Should all physical stock balances be reported on one line? 

  • 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: 2016_2742
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Can the same issuer / counterparty appear more than once in the top 10 of template C 71.00 based on currency?

The ITS states firms should report the name of the top ten issuers/counterparties of unencumbered assets or undrawn committed liquidity lines granted to the institution shall be recorded in column 010 in a descending fashion. The ITS also requires a currency to be assigned to the Issuers/counterparties. If you hold assets from a counterparty that are issued in different currencies do you report the counterparty more than once? Or do you report the currency of the largest proportion of the total.

  • 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: 2016_2741
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 02/03/2018

LCR treatment of cash pooling services

Due to limitations on the withdrawal of deposits, should individual deposits covered by a single cash pooling agreement be treated as individual deposits to which the outflow rates specified in Article 28 of the Delegated Regulation 2015/61 apply, or rather as a new type of product that would be covered by Article 23 of the Delegated Regulation? Alternatively, could inflows and outflows from cash pooling services be treated as interdependent inflows and outflows as per Article 26 of the Delegated Regulation? Or could the individual positive and negative balances covered by a single cash pooling agreement be considered on a net basis in order to determine the applicable outflows or inflows?

  • 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: 2016_2740
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 22/09/2017

Treatment of exposures to non-EU equivalent investment firms, non-EU equivalent credit institutions and non-EU equivalent exchanges.

1. With reference to EBA Q&A 677, what is the regulatory basis/rationale in your decision to treat a non-EU equivalent third country exposure to recognised exchange as an exposure to a corporate? Please reference the CRR/ Single RuleBook in your response.2. Does the treatment describer in Q&A 677 or non-EU equivalent recognised exchanges also apply to exposures to non-EU equivalent investment firms and non-EU equivalent credit institutions so that they will also be treated as exposures to corporates? Please reference the CRR/ Single RuleBook in your response.3. Should these exposures be reported (C07 CRSA) in the exposure classes Institutions or Corporates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2739
  • Topic: Credit risk
  • Date of submission:

Format of column 020 (exposure class) in Template 103 of Annex I

Regarding the EBA Benchmarking Exercise, in Annex I of the ITS some of the 18High Default Portfolios' are defined covering two exposure classes (Retail - Secured by real estate SME ; Retail - Other SME). In template C 103 column 020 the exposure class is to be reported. The given data point model does not include a value that combines these two exposure classes.

  • 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: 2016_2738
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Consideration of collateral in the potential future credit exposure

We seek clarification regarding the potential future credit exposure referred to in Article 274(2) of Regulation (EU) No 575/2013 (CRR) for all contracts included in a netting agreement. Should the collateral (given or received) be considered in the denominator of NGR? Is the proposed calculation of RC gross correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2735
  • Topic: Market risk
  • Date of submission:

Validation rules v2817_m & v2823_m between the Finrep conso & AE-CON conso reportings

We have 2 validation rules v2817_m & v2823_m that can't be solved between the Finrep conso & AE-CON conso reportings.For the Debt securities sum({F 32.01, r040, (c010, c060)}) = sum({F 01.01, c010, (r080, r094, r120, r160, r173, r177, r190, r220, r232, r236)}) [v2817_m] checks the total of debt securities in the Finrep with total of debt securities reported in AE F32.01  There are additional checks on details;For Central govs:if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r070, (c010, c060)}) = {F 04.01, r080,c010} + {F 04.02, r080,c010} + {F 04.03, r080,c030} + sum({F 04.04, c060, (r030, r170)}) [v2818_m]For Financial corporations:if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r080, (c010, c060)}) = sum({F 04.01, c010, (r090-100)}) + sum({F 04.02, c010, (r090-100)}) + sum({F 04.03, c030, (r090-100)}) + sum({F 04.04, c060, (r040-050, r180-190)}) [v2819_m]For corporations:if {F 00.01, r010,c010} = [IFRS] then sum({F 32.01, r090, (c010, c060)}) = {F 04.01, r110,c010} + {F 04.02, r110,c010} + {F 04.03, r110,c030} + sum({F 04.04, c060, (r060, r200)}) [v2820_m] In the Finrep report the covered bonds & asset backed securities are reported in 1 of the 3 above categories while in the Asset encumbrance tables these types of securities are part of a separate category. Those rules doesn't allow Banks to report anything in the AE for covered bonds and asset backed securities …Other assets sum({F 32.01, r120, (c010, c060)}) = sum({F 01.01, c010, (r020, r060, r092, r240-260, r290, r320-330, r360-370)}) [v2823_m] doesn't contain PPE and goodwill. Then total of assets in asset encumbrance can't be reconciled with total asset in the Finrep.  We considered the following check as a control that both amounts are more or less aligned: {F 36.01.c, r230,c180} ≡ {F 01.01, r380,c010}

  • 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: 2016_2732
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Classification of SME/Retail Corporates as 'Retail Deposits'

To be eligible for Article 153(4) CRR, do firms need to have externally verified annual sales numbers, and if so how frequently should firms assess eligibility?

  • 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: 2016_2731
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 09/12/2016

General principles governing resolution

BRRD Article 34.1.b. states that "creditors of the institution under resolution bear losses after the shareholders in accordance with the order of priority of their claims under normal insolvency proceedings, save as expressly provided otherwise in this Directive". I have two questions : Does the fact that "creditors of the institution under resolution bear losses [...] accordance with the order of priority of their claims under normal insolvency proceedings save as expressly provided otherwise in this Directive" means that creditors with the same ranking under insolvency be treated the same way under the bail-in, bridge bank or sale of business tools except if the BRRD explicitely excludes one specific liability from the application of the considered resolution tool or does the provision "save as expressly provided otherwise in this Directive" means that if the BRRD allows for a transfer / bail-in of "all or any liabilities" then similar liabilities can be treated differently ? Does the principle according to which "creditors of the institution under resolution bear losses after the shareholders" also applies to a bridge bank created under BRRD rules and to which further resolution tools, including possibly bail-in, are applied or does that apply only to the "initial" institution or until the bridge bank is not a bridge bank anymore ?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2728
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Including in the LCR calculation deposits from this category with residual maturities longer than 30 days

Should banks include in the LCR calculation deposits from this category with residual maturities longer than 30 days? Should outflow rate (40%) be applied to all deposits from this category or only to deposits with residual maturities shorter than 30 days?

  • 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: 2016_2727
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 09/12/2016

Monitoring and evaluation of mortgages in cases of portfolio-wholesale transactions

Is it possible to assign the preferential risk weight of 35% according to Article 125 (1) (a) of Regulation (EU) No 575/2013 (CRR) to exposures that have been purchased at a wholesale price based on a) samples as to whether the conditions laid down in Art 208 and 229 CRR are fulfilled and b) a warranty guaranteeing full compensation in case any of these exposures default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2726
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Application of exemption from monthly reporting frequency for AMML templates

Does the exemption from monthly reporting as mentioned in Article 16b(2) of Commission Implementing Regulation (EU) 2016/313, refer to the remittance frequency only or also to the reference dates/periods to be reported on?

  • 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: 2016_2725
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/06/2016