Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Validation rule v3694_s - v0532_m

During the validation of the C13 and C05.02 (Corep own funds and leverage, consolidated on prudential basis we obtained a validation), performed by our regulator, we obtained a validation error that is incorrect, namely: v3694_s Sign C 05.02 (010;020;090) (020;030;040;060) {C 05.02} >= 0 do not run rule The correction in C05.02 does not only reflect the temporary inclusion of subordinated loans which don’t fulfill the requirements of CRR / CRD IV, but should also reflect the temporary transfer of old-style hybrids to AT1 in a phased approach. When the old-style hybrid instruments fulfill the conditions to be recognized as Tier 2 capital under CRR/CRD IV, these instruments are taken into account in the fully loaded reporting as reflected on line {C01.00,r760,c010). However in a phased-in calculation, which is reported under the transitional measures, these instruments can temporarily still be recognized as Additional Tier 1 instrument. Therefore, the transitional adjustment related to Tier 2 will imply a decrease of Tier 2 capital and recognition as Additional Tier 1 capital (in 2014 only 20% remain in T2 and 80% will be transferred to AT1, in 2015 40% will stay in T2 and 60% will receive recognition as AT1, …) and thus the correction to be made to Tier 2 is negative. v0532_m: (c190) = (c200) + (c210) + (c220) + (c230) + (c240) + (c250) + (c260) + (c270) + (c280) + (c290) + (c300) + (c310) + (c320) + (c330) + (c350) + (c370) [[C 13.00 (r010-150;170-540)]] (1 error(s)) We assume that validation check in table C13 on field W51 (Exposure value subject to risk weights) is erroneous. The value in this field should totalize all exposure values in the fields from X51 till AI51 (ratings based method) plus AJ51 (unrated), AK51 (supervisory formula), AM51 (look- through) and AO51 (internal assessment approach). It’s however impossible to meet this requirement, since the fields from AK51 till AQ51 are blocked.

  • 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: 2014_1388
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Treatment of subordinated loans in respect of Art 133 (3) CRR

Could you please confirm that subordinated loans according to Art 62.a CRR, which are acknowledged as Tier 2 are not regarded as equity exposures according to Art. 133.3 CRR.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1384
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Short positions in financial institution capital instruments

(1) Where a bank holds an item which is treated as a financial institution capital instrument under CRR, can a guarantee or credit default swap over that instrument be considered a short position for the purposes of Articles 45(a), 59(a) or 69(a)? (2) Where a bank has an indirect holding of a financial institution capital instrument, can a guarantee or credit default swap over the host item be considered a short position in the underlying capital instrument for the purposes of Articles 45(a), 59(a) or 69(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1382
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 20/02/2015

PD substitution and eligibility of guarantors

Article 202(d) of Regulation (EU) No 575/2013 (CRR) suggests that where risk weighted exposure amounts are calculated under the IRB Approach, a guarantor must have an internal rating in order to be eligible as a guarantor for PD substitution. Can a guarantor, which is rated by an ECAI, and otherwise meets all eligibility requirements but is treated under the Standardised Approach by the institution, be used for PD substitution? How can a guarantee be recognised in this situation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1381
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/09/2015

Disclosure requirement on individual basis

What is the connection between the provisions of Article 13 and Article 433 of Regulation (EU) No 575/2013 (CRR)? When shall the institutions disclose all the information required by Part Eight and on what condition could the limited disclosure requirement be applied on individual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1379
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 27/03/2015

Missing Entity code

What should be reported in column 020 in table F 40.01 Annex III , if entity code is missing for an entity? Should the cell be left empty, if an LEI code is existing for the entity?

  • 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: 2014_1378
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/06/2016

CVA Standardised Method for Securities Financing Transactions (SFTs)

Article 382(2) of Regulation (EU) No 575/2013 (CRR) states that ‘an institution shall include securities financing transactions in the calculation of own funds required by paragraph 1 if the competent authority determines that the institution's CVA risk exposures arising from those transactions are material’. Assuming SFTs are included in the CVA Standardised CVA charge, clarification is required on the definition of the 'EAD' and 'M' inputs to the CVA Standardised Formula:Question 1: What definition of 'EAD' is applied for SFTs under the CVA Standardised Method? i.e. is it only the fully adjusted exposure value in accordance with Article 223(5) or can the exposure value take in account master netting agreements as set out in Articles 220 and 221 of the CRR be used ?Question 2: What definition of 'M' (the effective maturity of the transactions) is applied for SFTs in the CVA Standardised Formula? i.e. the definition of 'M' in Article 384(1) for non-IMM banks references Article 162(2)(b) which only refers to master netting agreements for derivatives.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1376
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 30/06/2017

Error in validation v0623_m (C.21.00 – MKR SA EQU)

Please confirm whether v0623_m is erroneous (refer to background on question for further detail) and if so, what the correct validation should be.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1374
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/03/2015

Treatment of Croatian currency - Kuna (HRK) and Croatian national market in Market risk reporting templates

We have noticed that there is no code for Croatian currency (HRK) as pre-defined separate reporting currency in templates C18 and C22 and no code for Croatian market as pre-defined separate reporting market in template C21.

  • 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: 2014_1370
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Derogation for small trading book business

According to the Article 94 of Regulation (EU) No 575/2013 (CRR) there is a possibility to calculate capital requirement in accordance with Article 92(3) point (a) CRR in respect of institution’s trading-book business. But the calculation of trading-book business is not enough precisely mentioned in Article 94 CRR. Should institution calculate this trading-book business based: (1) on overnight positions (as at the end of business day) or (2) on daily turnover in financial instruments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1367
  • Topic: Market risk
  • Date of submission:

Reporting of 10 largest exposures to institutions (correct counting in a case where 2 clients in a group of connected clients are institutions)

How should an institution count "top 10 exposures to institutions" in a case of an exposure to a group of connected clients in which an institution is a parent and there are at least 2 institutions in this group? a) As 1 (of 10) exposure to institutions – because a group of connected clients counts as one exposure when counting top 10 (no matter how many institutions there are in this group) b) As 2 (of 10) exposures to institutions - because there are two institutions in the group of connected clients with a parent institution.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1366
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Maturity-based calculation of general risk

Are the FX Forward, FX Swap and CIRS to be taken into consideration when computing the General Risk using the maturity-based method?

  • 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: 2014_1356
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 24/10/2014

Immediate obligor and ultimate obligor concerning exposures secured by mortgages on immovable property

In ‘Annex II – Reporting on own funds and own funds requirements’ we find the following instructions:‘3.4. Credit and counterparty credit risks and free deliveries: Information with geographical breakdown (CR GB)The term ‘residence of the obligor’ refers to the country of incorporation of the obligor. This concept can be applied on an immediate-obligor basis and on an ultimate-risk basis. Hence, CRM techniques can change the allocation of an exposure to a country. (…) Data regarding ‘original exposure pre conversion factors’ shall be reported referring to the country of residence of the immediate obligor. Data regarding ‘exposure value’ and ‘Risk weighted exposure amounts’ shall be reported as of the country of residence of the ultimate obligor.’What does this mean for an exposure secured by mortgage on immovable property where obligor and immovable property are located in different countries?

  • 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: 2014_1354
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/07/2017

In the case of a repurchase of CET 1 instruments, AT 1 instruments, or T 2 instruments for market making purposes, competent authorities may give their permission in advance to reducing own funds for a certain predetermined amount.

Would such a frame given in advance to reduce own funds for a certain predetermined amount for market making purposes result in a deduction from own funds at the time when permission is given or would a deduction from own funds be made at the time when the actual repurchase of capital instruments takes place? It should be noted that the question being posed is linked to the situation where a permission is given in advance to repurchase own capital instrument for market making purposes. The question being posed is not linked to a situation where a permission is given in advance to repurchase own capital instrument in order to reduce own funds on a permanently basis.

  • 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: 2014_1352
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 31/10/2014

10 largest exposures to institutions and unregulated financial sector entities

How to count 10 largest exposures to institutions? If a reporting institution has 7 large exposures to institutions, does it have to include into report its next 3 largest (but "non large") exposures (10 alltogether) or 10 largest (but "non large") exposures (17 alltogether)? the same applies to reporting of exposures to unregulated financial sector entities.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1351
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 08/05/2015

LE reporting - reporting of exposures exempted under Article 400(1)(c) - exposures carrying explicit guarantees of central governments

What is the correct reporting of an exposure to company A if this exposure is guaranteed by the explicit guarantee by central government (this central government with 0% RW) - such exposure is subject to an exemption under Article 400(1)(c)?

  • 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: 2014_1349
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Interest Rate Cashflows due within 30 days

Are interest rate cashflows shown in the same position in the In-/Outflow-Template as the corresponding redemption cashflows? Are the weighting factors for interest rate cash flows the same as for redemption cashflows.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1340
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

F 07.00: Validation Rules v0817_m, v0818_m, v0822_m, v0823_m, v0824_m

We assume that validation Rules v0817_m, v0818_m need to be corrected for F 07.00, column 110 and v0822_m, v0823_m, v0824_m for F 07.00, columns 080 and 090, because the sign >= does not work in this case for negative numbers. Can you please confirm?

  • 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: 2014_1331
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Large Exposures Reporting of Volatility Haircut applied to Exposure Value

The instructions for template C 28.00, column 300 and C 29.00, column 310 i.e. “(-) Funded credit protection other than substitution effect”, are currently unclear how volatility haircuts that are applied to the exposure value under CRM are reported.Some vendors have suggested that the CRM volatility haircut applied to the exposure value should be included as a positive value (+), while the volatility haircut applied to the collateral should be included as a negative value (-) within template C 28.00, column 300 and template C 29.00, column 310.This is the only way to satisfy the following validation rules:v0653_m{c330} = {c210} + {c240} + {c250} + {c260} + {c270} + {c280} + {c290} + {c300} + {c310} + {c320}v1683_m{c340} = {c220} + {c250} + {c260} + {c270} + {c280} + {c290} + {c300} + {c310} + {c320} + {c330}The current text used for “(-) Funded credit protection other than substitution effect”, in templates C 28.00 and C 29.00 simply states that "the institution shall report the amounts of funded credit protection, as defined in Article 4(58) of Regulation (EU) No 575/2013, that are deducted from the exposure value due to the application of Article 401 of Regulation (EU) No 575/2013". There is no reference to the volatility haircut applied to the exposure value under CRM. Therefore, can we suggest that the instructions to template C 28.00, column 300 and template C 29.00, column 310 are amended to provide clarification on how the volatility haircut applied to the exposure value under CRM is incorporated into the large exposures templates C 28.00 and C 29.00

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1327
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 04/10/2019

Classification of invoice discount facilities as full risk items

1. Should invoice discount facilities always be classified as full risk items or may such facilities be classified as medium/low or low risk if they may be cancelled with immediate effect when the assumptions used for setting the limit change? 2. Should the nominal value of an invoice discount facility as an off-balance sheet item be calculated as the difference between the contractual limits of the total credit volumes of clients and the amounts that have been paid to clients for the discounted invoices not yet due for payment from customers?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1324
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/10/2014