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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

Template F 16.01 - Interest income and expenses by instrument and counterparty sector

Template F 16.01 requires that interest income and expense for hedging derivatives that hedge interest rate risk are recorded separately in row 250 column 010 and 020. These amounts are hedging the interest income or interest expense for other items recorded in the same column. For example, an interest rate swap can be used to hedge an AFS debt security. Whilst the AFS debt security in row 020 column 010 has a positive amount the interest on the swap can be negative in row 250 column 010. This negative amount should be presented in interest income so that total interest income is disclosed correctly. Similarly in column 020 if a swap is used to hedge interest rate risk on a deposit the interest would be negative. Again this needs to be reported in interest expense to ensure total interest expense is disclosed correctly.EBA v3950_s and v3951_s signage validation requires positive amounts in row 250. Please can EBA advise on whether FINREP can permit negative amounts in row 250 for columns 010 and 020.

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

Excess General Credit Risk Adjustments - Standardised Approach (SA)

Can institutions use the excess of SA general credit risk adjustments over the 1.25% cap to reduce SA exposure value under own funds requirements, or reductions to SA original exposure value are just limited to specific credit risk adjustments? If so, where should the excess of general provisions, not considered as Tier 2 due to the 1.25% cap, be deducted (i.e. Retail class)?

  • 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

Transitional provisions on the introduction of IAS 19 revised

Which are the reporting dates that institutions should refer in the calculation of the applicable amount in accordance with 473 (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

Group Solvency template (C06.00) – information on the contribution of entities to solvency of the group (columns 300 to 400)

On what basis should the contribution of entities to solvency of the group (columns 300 to 400) be reported?

  • 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)

Incorrect references to the CRR

In Annex 1, C 05.02 'Grandfathered instruments: Instruments not constituting State Aid' there are some wrong references to the CRR articles, as follows: - row 020 and row 090 - instead of 'Article 489', it should be 'Article 486'; - row 050, row 060 and row 070 - instead of 'Article 49 of CRR', it should be 'Article 52 of CRR'. Limits for grandfathering of items within CET1, AT1 and T2 are in Article 486 of the CRR. Conditions for AT1 quialification are in Article 52 of the CRR.

  • 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)

Deduction of IRB Shortfall to Own Funds

In what cell, if any, of CA1 shall institutions deduct half of the amount of the IRB shortfall of credit risk adjustments to expected losses in T2 capital?

  • 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)

Template C07.00 Column 230: of which: with a credit assessment by a nominated ECAI

Column 230: of which: with a credit assessment by a nominated ECAI, is this column only reported for exposures where the ECAI rating was used to determine the risk weight?

  • 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)

Template C07.00 Column 240: of which: with a credit assessment derived from Central Government

Column 240: of which: with a credit assessment derived from Central Government, is this column only applicable to exposure classes institutions, public sector entities or regional governments and local authorities? Or should it also include corporates under CRR Article 122.2 where the risk weight was derived from the central government of the jurisdiction in which the corporate is incorporated?

  • 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)

Template C09.03 (CR GB3) - Breakdown of total own funds requirements for credit risk of relevant credit exposures by country.

Template C09.03 (CR GB3) column 010; is the requirement to report risk weighted assets (RWAs) or Capital Requirement (RWAs x 8%)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Template C 09.02 (CR GB2) – Row 040 Specialised lending under the slotting criteria

Should 'Corporate Specialised Lending' reported within row 040 exclude specialised lending under the slotting criteria?

  • 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)

C06.00 - Group Solvency : Information on affiliates (GS) template column 030 and column 070 to 240

Is the ‘YES/NO’ classification required for column 030 only relevant for purposes of identifying eligible minority interest?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Calculation of 17.65% CET1 threshold

In CRR article 48(2) it 19s defined calculation of threshold as follows:"2. For the purposes of paragraph 1, the threshold amount shall be equal to the amount referred to in point (a) of this paragraph multiplied by the percentage referred to in point (b) of this paragraph: (a) the residual amount of Common Equity Tier 1 items after applying the adjustments and deductions in Articles 32 to 36 in full and without applying the threshold exemptions specified in this Article;(b) 17,65 %."However in the instruction of the ITS on supervisory reporting on row 210 of CA4 is supported by Article 48(1) of CRR and explains the following:"This item contains the 17.65% threshold for holdings in financial sector entities where an institution has a significant investment, and for deferred tax assets that are dependent on future profitability and arise from temporary differences, to be applied after the 10% threshold.The threshold is calculated so that the amount of the two items that is recognised must not exceed 15% of the Common Equity Tier 1 capital, calculated after all deductions, not including any adjustment due to transitional provisions."As the respective article 48 points (1) or (2) do not refer to 15% threshold, this reference in annex 2, in row 210 of CA4, in last paragraph to, 1815% of the Common Equity Tier 1 19 should be read as '17,65% of the Common Equity Tier 1'?Or does the threshold 17,65% of row 210 of CA4 actually includes calculation of 15% threshold? In this case, how? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Scaling factor for IRBA securitisations with 1250% risk weight under the Ratings Based Method

Does an institution have to multiply the risk-weighted exposure amount of a banking book IRBA securitisation with a 1250% risk weight under the Ratings Based Method with the scaling factor of 1.06?

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

Inclusion of Specialised Lending in CR IP Losses template

Should Specialised Lending and Speculative Immovable Property Financing exposures be reported in the CR IP Losses template?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Calculation of foreign exchange position for non-FX derivatives denominated in foreign currency

Should non-FX derivatives denominated in foreign currency be treated as cash position or net forward position? Should it be treated in market value (as showed in balance sheet) or like FX swaps in principal amount (as showed in off-balance sheet)?

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

Template F 16.01 - Interest income and expenses by instrument and counterparty sector

Template 16.01 requires the interest to be broken down by interest income and expense and also by financial instrument. Institutions use derivatives to manage financial instruments designated at fair value. For those that do not qualify for hedge accounting they act as an economic hedge with changes in the fair value of the hedged item. Typically, derivatives are used to manage fair value movements of debt securities issued, which are designated at fair value. One part of this economic hedge is the recording of net interest income. In IFRS the derivative interest income is netted within interest expense against the debt security issued as these balances are managed together. As FINREP requires the interest to be split out by instrument there would be a negative derivative expense. This negative amount should be presented in interest income so that total interest income is disclosed correctly in row 270. However the amount in row 010 column 020 would cause EBA v3951_s signage validation to fail as it requires a positive balance. Please can EBA advise on whether FINREP can permit a negative derivative expense for derivatives (row 010, column 020).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Reference period for items reported on a cumulative basis

According to the Final Q&A 2013_619 (posted on 30/04/2014), ‘information submitted… referring to a certain period shall be reported cumulatively from the first day of the accounting year to the reference date’, ‘the FINREP templates should be reported on a cumulative basis’.However, the Final Q&A 2013_158 (posted on 14/02/2014), talking about ‘Amount of cumulative change in fair values’, says that ‘Retrospective application back to the date of initial acquisition’ or ‘to apply the requirements retrospectively from the earliest period practicable’.We also saw a reference about certain period in Annex V, Part 2, paragraph 86 of the ITS on Supervisory Reporting that made us doubt: ‘Change in fair value for the period shall include gains or losses from re-measurements of the instruments in the period’.Having these three different alternatives about reporting period’s calculation, which option would be the most appropriate to apply on ‘Amount of cumulative change in fair values’?

  • 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)

Lines 290 to 320 of the CR SA’ state

1/ For lines 290 and 310, are the columns "215" and "220" matching the exposures’ weighted amounts if they were not secured by a mortgage or is it necessary to declare the same weighted amounts shown in line 010 classified according to the category of the exposure’s original counterpart. 2/ For lines 300 and 320, is the column "215" matching the exposures’ weighted amounts if they were not in default or is it necessary to declare the same weighted amounts shown in line 010 classified according to the category of the exposure’s original counterpart. 3/ Lines 300 and 320 of the CR SA’ state concern defaulted exposures for which categories before being in default were as such: - Central governments and central banks - Regional and local administrations - Public Sector Entities - Institutions that are not subjected to an evaluation of short-term credit - Businesses/Corporates that are not the subjected to an evaluation of short-term credit - Retail (customers ) Can you confirm that defaulted exposures secured by a mortgage are not affected by lines 300 and 320 of the CR SA state? However, they will be reported in the column "020" of the line 90 of the CR GB 1 state.

  • 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)