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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

PD calibration sample

Given the definition of PD calibration provided in EBA/GL/2017/16 section 2.4 paragraph 8, and the requirements for the calibration sample provided in section 5.3.5, paragraph 88 of the same guidelines, for developing a TTC model, clarification is needed on the expectation on the implementation of the back-testing performed in the validation phase.: Shall the back-testing at portfolio level verify that the average PD over historical observation period is aligned with LRA DR or, instead, shall the comparison be made between PD estimates current at the validation date and the LRA DR? Does it change according to the rating philosophy? Shall the back-testing always be performed on a 1-year validation sample, regardless the type of TTC calibration philosophy and regardless the length of the calibration sample? How shall the rating philosophy be taken into consideration when assessing the outcome of back-testing at grade level? Provided that the main aim of the calibration is to reflect the LRA DR, is the any case where the alignment to 1-year default rate should get a higher weight in validation assessment, although in a TTC calibration philosophy?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures

Display of provision during substitution approaches

Due to the future application of the CRR3, the used of the IRB model will be limited. As example, some expositions (Corporates SME especially) considered with IRB method (and so displayed in C08A – CR IRBA form in COREP), are currently guaranteed by an institution or a sovereign which are also today considered with the IRB method. With CRR3, the debtor will probably stay with the IRB method (so still displayed in CR IRBA form in COREP), but there will be an outflow to the CR SA because the Basel method of the guarantor will be standard model. There will be an inflow in CR SA to display the metrics of the expositions after taking into account the characteristics of the guarantor (CRM). Around September 2021, we asked to your team, some precision about the “display of the provision during the substitution approach” under the reference 2021_6220. Our question result from the Q&A 2017_3335 which confirm the possibility to apply the substitution approach when the exposure and the guarantor are treated by the institution under different basel methods. Our Q&A has been rejected considering that the issue it deals with is already explained in section 3.1.1 of Annex II to Regulation (EU) No 2021/451 (ITS on Supervisory Reporting). Without mistake of our part and conversely of your affirmation, we are still considering the display of the provision non taking into account by the Q&A 2017_3335. For reminder, the display of the provision in COREP forms is different according to the Basel method applied: The value is displayed in column 0020 of C07 - CR SA uses the Basel method of the debtor Inversely for the C08 - CR IRB, the value is displayed in column 0290 (as memorandum item) uses the Basel method of the guarantor (if there is any)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

Opinion to Question 2020_5551, whether an institution is allowed to apply the supporting factor for SMEs and the supporting factor for infrastructure projects simultaneously.

A pending Question 2020_5551 asks an opinion whether an institution is allowed to apply the supporting factor for SMEs (Art 501) and the supporting factor for infrastructure projects (Art 501a) simultaneously. I share here my opinion to help the answer, as it would be important to our institution, and I think the answer is simplier than thought suggested on that question. The pending question I am referring to is under the link https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5551

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

Treatment for strategic long-term non-listed equity exposures under simple risk weight approach as per Article 155(2) CRR

Can a RW of 190% be applied to long-term strategic investments in non-listed equity exposures as per Article 155(2) CRR, provided that they are in a sufficiently diversified portfolio?

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

Validation rule eba_v0315_m working incorrectly in C07 templates in a column 0216 for derivatives

Could validation rule eba_v0315_m be modified for a column 0216? At the moment it does not work in situations when there are derivative exposures with SME supporting factor in a row 0110 but not in an of which row 0120.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

European Union Allowances (EUA) as credit risk mitigant

Could European Union Allowances (EUA) received by a credit institution as collateral be considered as eligible one from prudential point of view ? If yes, how EUA should be considered ? As financial collateral or as other physical collateral ?

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

Residential property

Artcile 4 (75) presents the definitions for Residential property - “residential property” means a residence which is occupied by the owner or the lessee of the residence, including the right to inhabit an apartment in housing cooperatives located in Sweden; Question ID: 2015_2304 has a aswwer:  "For the avoidance of doubt, the exposure has to be secured by a mortgage on residential property which “is or shall be occupied or let by the owner”. This excludes situations where residential property “may” be built in the future (i.e. mortgages on land) but includes mortgages on building sites on which residential property will be built for the future owner of the property, or on residential property under construction, provided in both cases that there is certainty that the owner will occupy or let the property. In this sense, the 35% risk weight cannot be applied to exposures towards real estate developers. This treatment does only apply to exposures fully and completely secured by mortgages on residential property, and not where units were to be exploited commercially. " If real estate company owns houses/apartments/flats and this company leases them to natural persons (for living) does these houses/apartments are consideres as residential properties or commercial properties in Your view? Clear Yes and No answer is needed.  

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

Exposure to multilateral development banks

What are the criteria to be assigned a 0% risk weight by the EU under this regulation?  What is the process to apply to be assigned a 0% risk weight?

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

The risk-weighted exposure amount of the CIU’s exposures in mandate based approach

Could the institution use the information from the CIU management company about the notional amount of derivative positions of CIU to assess the value of those derivatives in calculating risk-weighted exposure amount of CIU when using the mandate based approach in accordance with Article 132a(2) CRR? In particular, is the institution allowed to use the information from the CIU management company, that CIU doesn’t have derivatives in their portfolio and assess the value of those derivatives as zero in calculating risk-weighted exposure amount of CIU when using the mandate based approach in accordance with Article 132a(2) CRR?

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

Calculating risk-weighted exposure amounts under the standardised approach for exposures guaranteed by a Member State’s central government denominated in the domestic currency of that central government when the exposure is denominated in a different currency that is the currency of another Member State

For exposures guaranteed by a Member State’s central government where the guarantee is denominated in the domestic currency of that central government, the central government as protection provider shall be assigned a 0% risk weight if the exposure is denominated in a different currency that is the currency of another Member State?

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

Exposure to an entity that holds a loan portfolio composed of purchased or self-originated loans which are secured by real estate properties and their assignment to the regulatory asset class “exposures associated with particularly high risk”

Does an exposure representing funding to an SPV that itself originates reverse mortgages loans with returns linked to the development of the relevant housing market and a business case involving a potential sale/securitisation of the underlying portfolio (see “Background on the question”) fulfil the requirements to be assigned to the regulatory asset class “exposures associated with particularly high risk” in accordance with Article 128(3) CRR and its specification as set out in EBA/GL/2019/01, even though the bank has contractual agreements with the SPV in place (i.e. covenants and LTV restrictions) which have a certain risk mitigating effect?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR

Exposure to an entity that holds a loan portfolio composed of purchased or self-originated loans which are secured by real estate properties and their assignment to the regulatory asset class “exposures associated with particularly high risk”

Does an exposure representing funding to an SPV, that itself purchases loans originated for speculative immovable financing purposes, fulfil the requirements to be assigned to the regulatory asset class 'exposures associated wth particularly high risk' in accordance with Article 128(3) CRR and its specification as set out in EBA/GL/2019/01, even though the bank has contractual agreements with the SPV in place (i.e. covenants and LTV restrictions), which have a certain risk mitigating effect?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR

Exposure of the borrower to ESG factors

Does the assessment of exposure and mitigating techniques in the referenced articles apply to the impact of the borrower on ESG factors, or to the impact of ESG factors on the borrower? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring

Exposure Value in repurchase transaction

Under the accounting framework (IFRS) a repurchase transaction is accounted for as an off balance sheet commitment (encumbrance) for the debt securities given (or 'sold') and a liability for the debt towards the counterparty (representing the future 'repurchase' of the debt securities). With regards to such a transaction we have the following three questions, to confirm that our understanding is correct: A/ Is it correct that for the repurchase operation the final exposure value is to be calculated using the following elements:      E = the (dirty) market value of the debt securities given      C = the (dirty) cash borrowed in respect of the repurchase operation B/ Is this final exposure value E* to be presented as an counterparty credit risk on balance sheet exposure? C/ Does the debt securities itself also still have to be included as seperate exposures (with their respective risk weighted assets) (or does the calculated exposure value for the repurchase operation replace the direct exposure on the debt securities)?

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

PRUVAL - Matching Total fair values liabilities with FINREP

Should the validation Rule v6566_s check the sign of row 0150 (1.2 TOTAL FAIR-VALUED LIABILITIES) of template C 32.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

SA-CCR cap margin agreement

How do you calculate the cap for netting sets subject to a contractual margin agreement mentioned in Article 274(3) CRR?

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

Recognition of plots of land as real estate collateral

There are plots of land that are owned by individuals or businesses that have been purchased for future use without (e.g. dowry, future residential building for own use, commercial exploitation, etc) but without any current indication of what its use will be. It is a form of investment without any current indication of its exploitation. These plots of land are usually in the form of additional collateral for personal loans or business loans. Can these be recognised as commercial real estate collateral under article 126 if all minimum requirements are satisfied?

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

When to apply CCF to residential mortgage off balance sheet exposure

For off balance sheet exposures, when Article 125(2)(d) references 'the part of the loan' that is less than or greater than 80% of the property value, does this refer to exposure, or gross loan balances. Therefore, should the required CCF be applied before or after comparing the balance commitment to the property value?

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

Article 111 or about

What CCF and provisions should be allocated, if any, in year 1/2/3/4 considering this special situation that I cannot find in the regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR