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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

Applicability of the SME supporting factor for financing private purposes

Where a natural person’s business activities meet the criteria for an SME, does the SME supporting factor according to Article 501 CRR also apply to exposures from financing private investments of this natural person not directly related to that business?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6301
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

The use of the financial collateral comprehensive method for retail exposures

If an institution uses the combination of A-IRB and F-IRB approaches for its retail (A-IRB) and corporate exposures (FIRB), can this institution then only use the Financial Collateral Comprehensive Method (FCCM) for its corporate exposures? If yes, what should it do for its retail exposures secured by financial collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6279
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Purchase of credit receivables as a form of 'granting credits'

  Should the purchase of credit receivables be classified as 'granting credits' within the meaning of CRR's definition of credit institution? And if so, would a subject (a natural or legal person) whose activity is that of repeatedly purchasing credit receivables from a credit institution and concurrently taking deposits or other repayable funds from public, be required to obtain a license under Article 8 CRD?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6257
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/03/2023

Nature and treatment of off-balance financial leasing exposures (generated by the lag between the order of the asset and the rental starting date)

Should off-balance financial leasing exposures (generated by the lag between the order of the asset and the rental starting date) be considered as a “credit line” and hence fall into Article 166.8(d) of the CRR or as an “undrawn credit facility” and hence fall into Article 166.10?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6239
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

CRM for off balance sheet commitments

1) Can the part of the off-balance exposure that is covered by the (to be vested) mortgage inscription be taken into account as 'fully secured and completely secured by mortgage' under Article 125(1) CRR?    2) Can the part of the off-balance exposure that is covered by the (to be vested) mortgage guarantee be taken into account as credit risk mitigation under Article 203 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6234
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

Original Maturity for off balance sheet items

1) Are loan commitments that constitute (accepted or unaccepted) loan offers to clients to be considered off balance sheet items, which fall under the definition of 'undrawn credit facilities' of Annex 1?    2) The 'original maturity' that is used for the allocation of 'undrawn credit facilities' to either medium risk, or medium/low risk is determined on the basis of the maturity of the commitment or on the basis of the underlying loan of the offer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6233
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022

FCCM volatility haircuts for eligible rated and unrated securitisation collateral

Does the FCCM approach apply to unrated senior securitisation tranches that qualify as eligible collateral?  If so, which supervisory volatility haircuts apply since there is no CQS associated with these under Sec-SA? In addition, the new securtisation mappings of ECAI ratings to CQS 1-17 have not been translated into Table 1 of Article 224, which continues to refer to CQS 1-4 seemingly under the old securitisation rules, which do not reflect maturity and tranche seniority.  Which supervisory volatility haircuts apply under the new CQS mapping for rated securitisation tranches?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6201
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 22/02/2022

Classification of derivatives on precious metals without physical underlying under SA-CCR

For Credit Risk calculation and in order to classify derivatives into the proper Risk Category (Commodity vs. FX Risk) under SA-CCR. Can you please advise on the category to use when derivatives on Gold do not have physical underlying ? Example with a Gold Option for which only the currency for Gold is used (XAU) and where Gold is physically not existing. Also, can you please advise if the same logic have to be applied for other precious metals (not physical) like Silver or Palladium ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6190
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 22/02/2022

Cut-off date for the implementation of the adjustment for massive disposals

The last part of the first subparagraph of Article 500 states that "The adjustment referred to in the first subparagraph [(i.e. Adjustment for massive disposals)] may only be carried out until 28 June 2022 and its effects may last for as long as the corresponding exposures are included in the institution's own LGD estimates".  How is 28 June 2022 to be interpreted? Is it a repetition of point (b) of subparagraph 1 (i.e. "the dates of the disposals of defaulted exposures are after 23 November 2016 but not later than 28 June 2022") or it represents the cut-off date by which the adjustment can be estimated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6174
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Risk weights for exposures towards Member States’ central governments and central banks denominated and funded in the domestic currency of that central government and central bank.

Shall exposures towards Member States’ central governments and central banks denominated in the domestic currency of that central government and central bank be given a 0% risk weight if they are funded by equity denominated in the same currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6160
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Scope of application of EBA guidelines on loan origination and monitoring

Are sections 4, 5 and 8 of the EBA guidelines on loan origination and monitoring not applicable to agreements referred to in Article 2(2)( h) of Directive 2008/48/EU, while all other parts of the guidelines are still applicable to those agreements?   

  • 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
  • ID: 2021_6130
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/01/2022

Treatment of an institution’s investments into EU AIF managed by a non-EU AIFM and into closed-ended CIUs

Should not the investment of an institution into a closed-ended CIU which has been marketed in accordance with Article 42 of AIFMD, but is not marketed anymore due to the end of its marketing phase, remain eligible to apply the look-through to the underlying exposures of the CIU, provided the other relevant conditions for looking-through continue to be met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6057
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Calculation of NPV loss in case of (internal) refinancing

Which NPV loss should be taken in order to calculate the NPV loss if the 1% threshold is breached and the forborne loan contract should be placed in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2021_6045
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Calculation of the relative threshold in case specific cases.

How should be calculated the relative threshold for a client who has fees or quotes in default arising from off balance sheet exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/171 - RTS on the materiality threshold for credit obligations past due
  • ID: 2021_6025
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/04/2023

Exposures in default secured by mortgages on residential property

How to classify an exposures, that is secured by mortgages on residential property and, according to the Article 124(2) of Regulation (EU) No. 575/2013 (CRR), is assigned a 150% risk weight and, at the same time, qualifies as 'Exposures in default' and meets the criteria listed in Article 127(1)(b) or (3) CRR, to assign it a 100 % risk weight?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6018
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/03/2023

Point in time when facility or limit is considered to be a commitment

Does a bank’s legally binding offer for a facility or limit constitute a commitment only after the client has accepted the bank’s offer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5836
  • Topic: Credit risk
  • Date of submission:

Treatment of committed facilities with unadvised limits

Are committed facilities with unadvised limits considered to be regulatory off-balance sheet items and do they have to be included in the conversion factor estimation under Advanced-IRBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5837
  • Topic: Credit risk
  • Date of submission:

treatment of uncommitted facilities / limits

Are uncommitted facilities or limits considered to be regulatory off-balance sheet items and do they have to be included in the conversion factor estimation under Advanced-IRBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5835
  • Topic: Credit risk
  • Date of submission:

Maturity calculation under IRB for exposures that only have contractual cashflows in the form of fees

Does Article 162(2)(a) of Regulation (EU) No 575/2013 (CRR) apply to exposures for which cash flow schedules contractually payable by the obligor are only fee-related (e.g., as in the case of guarantees)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5773
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/12/2021