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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

Maturity Bucket of Call Deposits for Large Exposure Reporting

What is the correct maturity bucket to report call (on-demand) deposits in Large Exposure Reporting template LE4?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_2644
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 07/04/2017

Definition of a 'Deposit Broker'

What is the definition of a deposit broker?

  • 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_2642
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 23/09/2016

Risk weighting under the Standardised Approach for credit risk for an exposure secured by a mortgage on a residential property which is a second home (for instance, a holiday home).

Can a second home be a residential property under Article 4(75) of Regulation (EU) No 575/2013 (CRR) and thus a respective mortgage benefit from the 35% risk weight under article 125(1)(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2641
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Relevant competent authority to determine the same risk weight treatment as the central government

Who is the relevant competent authority to determine if the same treatment of regional government exposure and central government exposure can be applied? The national supervisor, the European Commission or the ECB?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2637
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Mark-to-Market Method: Residual Maturity for Physically Settled Contracts

Which maturity should be used to determine the percentage as per Table 1 in Article 274(2) of Regulation (EU) No 575/2013 for derivative instruments that are settled with cash instruments for which a maturity can be determined, e.g. a cash debt security? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2634
  • Topic: Market risk
  • Date of submission:

Validation rules EBA_V4399 and EBA_V4400 warning on the tables P 02.04 and P 02.05

The Annex I of the "Guidelines on harmonised definitions and templates for funding plans of credit institutions under recommendation A4 of ESRB/2012/2" contains disclosure tables for pricing of Loan Assets "Table 2B1 (P 02.04)" and pricing of Deposit Liabilities "Table 2B2 (P 02.05)". Validation rules EBA_V4399 and EBA_V4400 check if the figures submitted are greater than or equal to zero. The "Guidelines on harmonised definitions and templates for funding plans of credit institutions under recommendation A4 of ESRB/2012/2" defines the data to submit as follows: - The projection of high-level yields on assets, with a 1-year horizon. Firms should report the all-in yield received/paid and should not report a spread. - Projection of high-level costs of funding, with a 1-year horizon As this tables aim to provide interest rates and as interest rates could be negative, we think that the validation rules V_4399 and V4399 should be adjusted.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2633
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 05/10/2018

Calculation of derecognised fiduciary assets

Are institutions required to calculate the value of their fiduciary assets in accordance with the leverage ratio framework even though the assets are already derecognised pursuant to Article 429a(1)(i) of the CRR?

  • 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_2631
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Validation rule v4574_m

Is validation rule v4574_m correct?

  • 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_2630
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Treatment of decreases of impairments in the calculation of the exposure value

In the context of published Q&A 2014_1087 how should a credit institution treat decreases of impairments, value adjustments or provisions (in case of reduced identified losses) recognised during the year, i.e. in the interim period, in the case where the competent authority has not given its permission to include the interim profit into the calculation of Common Equity Tier 1 capital, and the credit institution has not reflected the amounts with a corresponding "immediate reduction in Common Equity Tier 1 capital" although the changes in impairments, value adjustments or provisions for off-balance sheet items are reflected in interim profits or year-end profits?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2016_2629
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 23/09/2016

Asset encumbrance Reporting vs. Finrep Reporting – Definition of equity instruments not aligned

The following validation rule is not correct:v2816_m: sum({F 32.01, r030, (c010, c060)}) = sum({F 01.01, c010, (r070, r093, r110, r150, r172, r176, r235)})’.This validation rule excludes row 260 of F 01.01. An entity has to disclose ‘Investments in subsidiaries, joint ventures and associates’ in this row.By definition, row 260 of F 01.01 includes equity shares that are representing the ownership in subsidiary, joint ventures or 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)
  • ID: 2016_2628
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Retail exposures above EUR 1m - definition and understanding

Would a private individual client need to be regarded as "non retail" if the original exposure is above EUR 1 million (line EUR 2m) or could he stay in the "Retail" exposures class if his EAD is below EUR 1million (EAD close to zero) or the drawn amount is below euro 1m (drawn amount below EUR1m)?Clarity would be appreciated for both the standardised and IRB approach.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2626
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/10/2016

State guarantee of newly issued liabilities

Should liabilities issued under Article 32(4)(d)(ii) of Directive 2014/59/EU (BRRD) meet the criteria of Additional Tier 1 or Tier 2 instruments?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2622
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 28/01/2022

Use of resolution tools without issuing a formal decision

In light of Article 32(1) and Article 82 of Directive 2014/59/EU (BRRD), should the decision initiating resolution spell out which resolution tool/s, among those listed in Article 37(3) BRRD, will be applied, or is it possible to apply resolution tools without issuing a formal decision?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2621
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Direct fiscal impact and systemic implication in Article 3(6)

How can the terms “direct fiscal impact” and “systemic implication” in Article 3(6) be transposed in a way that removes ambiguity?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2620
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Special resolution regimes for credit institutions not covered by the Directive / partly resolved via insolvency

Does Directive 2014/59/EU (BRRD) prevent Member State to adopt special resolution regimes (including, e.g., bail-in) for credit institutions (i) that are not covered by the Directive; or (ii) in scope of the BRRD, whose preferred strategy is liquidation under national insolvency proceedings?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2619
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Toleranzschwellen bei Korrekturmeldungen gemäß Verordnung (EU) Nr. 680/2014

Unterhalb welcher Materialitätsschwellen dürfen Korrekturmeldungen gemäß Verordnung (EU) Nr. 680/2014 unterbleiben? Ab welchen Aufwandsschwellen, die für die nachträgliche Korrektur und Einreichung zu erbringen wären, kann die Einreichung korrigierter Meldungen unterbleiben?

  • 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_2613
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Exposure Value under the Equity method of accounting

What exposure value should be used for Large Exposure purposes in situations where there is a difference between the accounting value used for IFRS accounting purposes and the value used for FinRep regulatory purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2612
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Counterparty details for central bank eligible assets in Concentration of Counterbalancing Capacity template C 71.00

In the event that an institution pre-positions retail customer credit claims into a standard central bank emergency liquidity operation, which counterparty should be reported as the counterparty to the assets in template C 71.00?

  • 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_2611
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

Reporting of currency for undrawn committed facilities in Concentration of Counterbalancing Capacity template C 71.00

What currency identifier should be reported on template C 71.00 for an undrawn committed facility that is available to draw in multiple currencies and how should it be reported on significant currency returns?

  • 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_2609
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 12/01/2018

OSII capital buffer

Is Article 131(8) of Directive 2013/36/EU applicable on a situation, where an Other Systematically Important (“OSII“) institution in a member state is a member of a OSII group with no EU parent institution, but with an EU parent financial holding company in another member state instead?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2607
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 01/09/2017