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List of Q&A's

Clarification regarding the legal opinion mentioned in Article 305 of Regulation (EU) No 575/2013 (CRR)

Is it correct to assume that the specific legal opinion mentioned as a prerequisite in Article 305(2)(c) CRR only needs to confirm that the other prerequisites 'individual client segregation' in Art 305(2)a) and the facilitation of the portability of client assets under Art 305(2)(b) are in place and fulfilled (in a sense that the respective legal position of the client is enforceable under respective law(s)), or does the legal opinion need to address additional legal questions beyond that scope? In the latter case what kind of legal questions beyond Art 305(2)(a) and (b) would such legal opinion need to address?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1102
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 01/08/2014

Validation Rule v2245_h

Should column 090 from form CR GB 2 still be in the scope of validation rule v2245_h? As the rule validates a sum and column 090 contains percentages it cannot be 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2014_1101
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

FINREP Template 13.2 and 13.3

The difference between the templates 13.2 and 13.3 and the purpose of template 13.3 is not clear. Can you please explain the following questions.1.)Template 13.2 “Collateral obtained by taking possession during the period [held at the reporting date]”: We have understood that “during the period” means Information about obtained Collateral year-to-date (ytd). That means from 1. January to Reference date. Is this correct?2.)Template 13.3 “Collateral obtained by taking possession [tangible assets] accumulated”: We have understood that “accumulated” means life-to-date (ltd). Is this correct?3.)The heading of Template 13.3 is “Collateral obtained by taking possession [tangible assets] accumulated”. In de ITS part 2.84 you explain, that this template excluding those classified as “Property, plant and equipment”. For our understanding the definition of tangible assets are the same definition of Property, plant and equipment. Is the heading incorrect? If not, can you please confirm the purpose of this Template.

  • 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_1094
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 25/11/2016

Validation Rules: v0219_m, v0221_m

Both rules validate the Surplus(+) / Deficit(-) of certain capital:- v0219_m for CET1 Capital- v0221_m for T1 CapitalThe question stands: Should the range of percentages from Article 465 CRR be implemented in the validation rules for each type of capital or should the fixed percentages in Article 92 CRR be upheld?

  • 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_1093
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Different ID

Why "Public sector entities" dimension in the table C 07.00 does not have same type of linking to the table C 02.00 as does have for example "Regional governments or local authorities" dimension?

  • 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_1090
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Deposits received as collateral

Under 423(6) of Regulation (EU) No 575/2013 (CRR) should the deposits received as collateral be calculated as net posted collateral in order to treat posted and held cash collateral symmetrically? What if more cash collateral is posted than held? Thus should all other posted level 1 collateral not be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1089
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/04/2015

Fiduciary loans and deposits

Considering that for FINREP reporting the fiduciary loans and deposits are explicitly excluded from Balance Sheet could you please advice whether the same treatment applies to COREP (including Large Exposures) reporting? That is, if fiduciary loans and deposits should be excluded from all COREP and Large Exposure reports.

  • 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_1088
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Specific credit risk adjustments

Which item in the CA1 report should be used for reporting "immediate reduction in Common Equity Tier 1 capital" as described under Article 1 paragraph 1 second subparagraph of the Commission Delegated Regulation (EU) No 183/2014, in order to reduce the amount of exposure for specific credit risk adjustments for the purposes of calculation of risk-weighted assets?

  • 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: 2014_1087
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/11/2015

Annex II and VIII of the ITS on supervisory reporting under the CRR

According to the Article 395 paragraph (5) point a) of CRR the limit to large exposure may be exceeded for the exposures on the institution's trading book – among others - if the exposures on the non-trading book do not exceed the limit laid down in paragraph (1). How shall the excess of limit to the large exposure on the non-trading book after CRM be reported in the CA2 template?

  • 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_1085
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/10/2014

Implementing Technical Standards (ITS) on additional liquidity monitoring metrics

Concerning the instructions for the counterbalancing capacity by issuer/counterparty (CCC). Can the same issuer/counterparty appear more than once in the top 10 in this CCC by issuer/counterparty report?

  • 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_1084
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 18/12/2015

Validation rule v3995_u

Please check the appropriateness of validation rule (v3995_u) "{C 27.00, c010} is a row identifier, and must be unique for each row in the table"

  • 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_1080
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 26/09/2014

Supervisory powers Liquidity

Does Article 412(5) of Regulation (EU) No. 575/2013 (CRR) prohibit the competent authorities from imposing a “Liquidity-Add-on” (e.g. LCR-requirement above 100%; similarly to a Capital-Add-on according to Article 104(2) of Directive 2013/36/EU (CRD) according to Article 104(1)(k) and/or Article 105?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1077
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 25/07/2014

Partial and full write-off reporting in COREP

From the paragraph 49 of Part 2 of Annex V of the Draft ITS on Supervisory reporting and the answer to the question 2013_202 it is clear, that accumulated written-off amounts shall be reported in F 07.00 until the total extinguishment of all the institution's rights (by expiry of the statute-of-limitations period, forgiveness or other causes) or until recovery. Does the same principle hold for the COREP tables C09.01 (columns 060, 070)?

  • 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_1076
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Eligible collateral for the purpose of credit risk mitigation

Are American Depository Receipt (ADR) and Global Depository Receipt (GDR) considered as equity for the purpose of credit risk mitigation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1073
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 25/07/2014

Treatment as own funds under Regulation (EU) No 575/2013 (CRR)

Confirmation is sought that instruments that initially qualified for transitional treatment in a higher own funds category according to CRR transition rules in Articles 484ff, but for which documentation had to be altered to a lower own funds category as instructed by a court ruling following a litigation, are to be reported as fully compliant with that lower own funds category. More background information on the instruments will be made available directly to EBA.

  • 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_1071
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/06/2014

Reporting of loans collateralised by real estate

Should the loans reported in C 60.00, rows 1260 and 1270 be reported in full regardless of the value of the real estate collateral, or only up to the value of the collateral?

  • 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_1070
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Validations

The validation rule v2863_m {F 32.04.a, r140,c010} <= {F 09.02, r080,c010} is incorrect as per the background on this question. Please can the rule be deleted.

  • 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_1066
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 02/10/2015

FINREP - F 09.02 Loan commitments, financial guarantees and other commitments received

FINREP Template F 09.02 - Financial guarantees received. In the position 'Financial guarantees received' items that meet the definition according to article 58 of Annex V of the ITS on Supervisory reporting should be reported. In this context, in case the bank has a surety contract, which is a legally binding agreement that the signee will accept responsibility for another individual's contractual obligations (usually the payment of the loan contractual obligations if the principal borrower falls behind or defaults), should it be reported in the position 'Financial guarantees received' or in the position 'Other Commitments received'? Also in case of several surety contracts related to one loan obligation that aren't prioritized and have equal legal force which allocation principles should be applied according to article 63 of Annex V of the ITS on Supervisory reporting.

  • 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_1065
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Inclusion of partial write-offs in credit risk adjustments

Are partial write-offs of loans in the banking book, accounted at amortised cost, to be included in the determination of specific and general credit risk adjustments set out in Article 110(4).

  • 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: 2014_1064
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/12/2014

Retail Depoists - EUR1 million limit

With reference to the definition of "Retail Deposits", does the EUR1 million limit apply to 'natural persons'? Or does it solely apply to SMEs and companies eligible for the treatments set out in Article 153(4) 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
  • ID: 2014_1062
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 24/10/2014