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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

Large exposure reporting – Criteria for reducing the value of an exposure secured by commercial immovable property

Is Article 194(3)(b) relevant for accepting or rejecting commercial immovable property to reduce the value of an exposure secured by commercial immovable property according to the Article 402(2) when an institution uses the standardised approach for calculating credit risk capital requirements?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1659
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 22/04/2016

Determination of client for large exposures purposes regarding exposures constituted by non recourse financing of leasing-SPEs

1. Can a financing transaction where the institution contractually agrees to abstain from recourse to its legal obligor to the extent that payment obligations of a third party (the lessee) to the institution’s legal obligor (the lessor) are not fulfilled, i.e. where the institution takes over the credit risk stemming from its obligors´claims against a third party, be regarded as “other transaction where there is an exposures to underlying assets” within the meaning of Article 390(7) of Regulation (EU) No 575/2013 (CRR)?2. Is it admissible to regard the structure of such a transaction as not constituting an additional exposure to the leasing-SPE or any other third party within the meaning of Article 390(7) CRR in connection with Article 7(1) of Regulation (EU) No. 1187/2014 , where a. the payment flows from the underlying asset to the investing institution are separated from the leasing-SPE, in a way that the exposures to the lessee are managed by the leasing-SPE, but the payments are made by the lessee directly to an account of the leasing-SPE kept at the institution on which the institution has a lien according to its general terms and conditions of business, and b. the SPE is bankruptcy remote, in particular according to the documented and detailed information available to the institution, the bankruptcy of the parent company should only have a negligible influence on the leasing-SPE?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1635
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Exemptions from the application of Article 395(1)

Could exposures of an institution fully guaranteed by its parent undertaking - considering the substitution approach under Article 403(1)(a) of Regulation (EU) No 575/2013 (CRR) – be exempted from the large exposures provisions and in this way from the application of Article 395(1)? Furthermore, may the guarantees provided by the parent institutions from another Member State be handled in Article 403 of the CRR as a third party guarantee?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1592
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 10/07/2015

Interaction of Article 227 of the CRR (0% volatility adjustment under FCCM) and Article 401(3) (stress test of realisable value of collateral)

Our question concerns the application of Article 227 of the CRR (0% volatility adjustment under FCCM) and the interaction with the collateral stress test described in Article 401(3). The latter requires collateral values to be stressed, and the impact on Article 395(1) to be determined. It follows that the own funds requirement for large exposures in the trading book (calculated under Article 397 of the CRR) is adjusted upwards to take account of the stressed collateral values. Where the criteria set out in Article 227 of the CRR are met and 0% volatility adjustment is applied to repo/reverse repo transactions, is this exposure value taken as the base case for comparison with the stressed collateral impact calculated under Article 401(3)? Or are these two articles to be read in the reverse order, such that 0% volatility haircuts per Article 227 are also applied in the collateral stress test (Article 401(3))?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1573
  • Topic: Large exposures
  • Date of submission:

On-balance sheet netting and exemption from the Large Exposures limits

Are on-balance sheet (OBS) netting agreements, where there are maturity mismatches between loans and deposits, eligible the exemption from the large exposures regime as laid down in Article 400 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_1508
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 06/02/2015

On-balance sheet netting and exemption from the Large Exposures limits - question 1

Are on-balance sheet (OBS) netting agreements, where both legs are denominated in different currencies, exempted from the application of Article 395(1) 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_1505
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 06/02/2015

Groups of connected clients when a client is connected through various criteria (interconnection through control and / or economic interconnection)

As defined in Article 4(1)(39) of Regulation (EU) No 575/2013 (CRR), clients can be included into ‘groups of connected clients’ through criteria of control (Article 4(1)(39)(a)) or economic interconnection (Article 4(1)(39)(b)).What is the correct treatment of exposure to a client in case when the client is connected with other natural or legal persons through criteria of control and / or economic interconnection?Should the institution include and report all those clients connected with particular client as one ‘group of connected clients’ regardless of criteria of connection (control vs. economic interconnection) or should the institution include and report particular client in two (or more) groups where one group includes clients that are connected with particular client through criteria of control and the other separate group (or more groups) is formed of clients that are connected with particular client through criteria of economic interconnection?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1443
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 24/11/2017

Large exposures - major trading currencies in overnight transactions

How are the major trading currencies to be determined under Article 400(2)(f) of the CRR? Clarification is needed on what is to be considered a major trading currency under Article 400(2)(f).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_837
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 22/08/2014

The use of the Collateral Simple and Comprehensive Methods under the Large Exposure regime

Does the phrase "where it is permitted to use" referred to in the third sub-paragraph of Article 403(1) of Regulation (EU) No 575/2013 (CRR) intend to prescribe that the treatment for collateralised exposures specified under Article 403(1)(b) is available for: • those institutions which are allowed to use both the Financial Collateral Simple and Comprehensive Methods?; or • collateral types which are eligible for both methods?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_793
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 20/04/2021

Large exposures - excluding exposures if fully deducted from own funds

May a credit institution exclude exposures from large exposure calculations which are fully covered by own funds (i.e. full deduction of own funds for this large exposure amount) and which are not used otherwise (e.g. for minimum capital requirements)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_787
  • Topic: Large exposures
  • Date of submission:

Large exposure reporting – reporting of central government and natural or legal persons controlled by the central government or interconnected with it

As large exposure reporting is based on a client data – how should an institution report exposure to the central government for large exposure purposes? Should it report the total exposure to the central government (and treat it as a single entity) or should it report exposures to all the entities which form the central government? What about in the case of group of connected clients which includes the central government and entities controlled/otherwise interconnected with it? As defined in Article 4(39) of Regulation (EU) No 575/2013 (CRR), central government can be included in "n" groups of connected clients. What is the correct reporting in such a case?

  • 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: 2013_681
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/07/2014

Large Exposures – Disclosure of counterparty names

Where the credit institution does not have consent to disclose the clients names, what should it report here?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_672
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Exposure for Large Exposure Reporting - Accrued interests

Article 389 of the CRR states that for Large Exposure Reporting, the exposure should be identical to those in the standardised approach (Part II, Title 2, Chapter II) just without applying risk weights. According to Standard Approach for assets the risk position is defined by the balance sheet value including accrued interest and impairments being deducted. Can you confirm that this is also the definition for Large Exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_638
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Inclusion of indirect holdings in the large exposures regime

Do indirect holdings have to be included in the large exposure regime based on Article 389 of Regulation (EU) No. 575/2013 (CRR) if they are held against a financial sector entity (that is fulfil the definition in Article 36 (1)(h) or (i) of the CRR), but are not deducted from own funds and instead risk weighted according to Articles 48(4), 46(4) or 49(4) of the CRR? If the answer is yes, can the financial sector entity being regarded as the relevant client for large exposure purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_624
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 11/04/2014

Large Exposures - clients to CCPs

May a client relying on Article 305(2) to calculate own funds requirements for its trade exposures for CCP-related transactions with its clearing member in accordance with Article 306, rely on the exemption in Article 400 as regards such CCP-related transactions? Legal Reference: Article 295(1), 400, 305 and 306

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_365
  • Topic: Large exposures
  • Date of submission:

Reporting of the 10 largest exposures to institutions and the 10 largest exposures to unregulated financial institutions

The issue is that the term and definitions for "institution" and "unregulated financial entity" are not complementary and thus could cover the same counterparts. Could EBA confirm that they don't want to have the same entities reported in the 2 groups ("institutions" and "unregulated financial entities") and clarify both terms?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_211
  • Topic: Large exposures
  • Date of submission:

Definition of a large exposure

Please can you confirm if the large exposure threshold for reporting is 10% of eligible capital as mentioned in Article 392 or €300m?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_57
  • Topic: Large exposures
  • Date of submission: