Skip to main content
European Banking Authority logo
  • Extranet
  • Log in
  • About us
    Back

    About us

    The EBA is an independent EU Authority.  We play a key role in safeguarding the integrity and robustness of the EU banking sector to support financial stability in the EU.

    Learn more
      • Mission, values and tasks
      • Organisation and governance
        • Governance structure and decision making
        • EBA within the EU institutional framework
        • Internal organisation
        • Accountability
      • Legal and policy framework
        • EBA regulation and institutional framework
        • Compliance with EBA regulatory products
      • Sustainable EBA
      • Diversity and inclusion
      • Careers
        • Vacancies
        • Meet our team
      • Budget
      • Procurement
    Close menu panel
  • Activities
    Back

    Activities

    To contribute to the stability and effectiveness of the European financial system, the EBA develops harmonised rules for financial institutions, promotes convergence of supervisory practices, monitors, and advises on the impact of financial innovation and the transition to sustainable finance.

    Start here
      • Single Rulebook
      • Implementing Basel III in Europe
      • Supervisory convergence
        • Supervisory convergence
        • Supervisory disclosure
        • Peer Reviews
        • Mediation
        • Breach of Union Law
        • Colleges
        • Training
      • Direct supervision and oversight
        • Markets in Crypto-assets
        • Digital operational resilience Act
      • Information for consumers
        • National competent authorities for consumer protection
        • How to complain
        • Personal finance at the EU level
        • Warnings
        • Financial education
        • National registers and national authorities responsible for handling complaints related to credit servicers
        • Frauds and scams
      • Research Workshops
      • Ad hoc activities
        • Our response to Covid-19
        • Brexit
    Close menu panel
  • Risk and data analysis
    Back

    Risk and data analysis

    To ensure the orderly functioning and stability of the financial system in the European Union, we monitor and analyse risks and vulnerabilities relevant for the regulation of banks and investment firms. We also facilitate information sharing among authorities and institutions through supervisory reporting and data disclosure.

    Learn more
      • Risk analysis
        • 2024 EU wide transparency exercise
        • EU-wide stress testing
        • Risk monitoring
        • Thematic analysis
      • Remuneration and diversity analysis
      • Pillar 3 data hub
      • Reporting frameworks
        • Reporting Time Traveller
        • DPM data dictionary
      • Data
        • Registers and other list of institutions
        • Guides on data
        • Aggregate statistical data
        • Secondary reporting: data from Competent Authorities to the EBA
        • Data analytics tools
    Close menu panel
  • Publications and media
    Back

    Publications and media

    Communicating to all our audiences in the most effective way and using the most appropriate channels is crucial for us. Through our publications, announcements, and participation in external events, we are committed to reaching out to all our stakeholders to report about our policies, activities, and initiatives.

    Learn more
      • Publications
        • Guidelines
        • Regulatory Technical Standards
        • Implementing Technical Standards
        • Reports
        • Consultation papers
        • Opinions
        • Decisions
        • Staff papers
        • Annual reports
      • Press releases
      • Speeches
      • Interviews
      • Events
      • Media centre
        • Media gallery
        • Media resources
    Close menu panel

Breadcrumb

  1. Home
  2. Single Rulebook Q&A
  3. 2023_6739 Display of provision during substitution approaches
Question ID
2023_6739
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Credit risk
Article
430
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
Article/Paragraph
.
Type of submitter
Credit institution
Subject matter
Display of provision during substitution approaches
Question

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)
Background on the question

    By this was, resulting to the substitution approach with a guarantor using a Basel method different of the one of the debtor, the provision is not displayed in some case, or displayed twice in others.

    There is here a resume of our issue:

    Substitution Approach

    Before CRM -> After CRM

    Display of provision according to his Approach

    Debtor IRB ->  Guarantor Standard

    • Not displayed in C08 - CR IRB
    • Not displayed in C07 - CR SA

    The provision is NOT displayed

    Debtor Standard  -> Guarantor IRB

    • Display in C07 - CR SA
    • Display in C08 - CR IRB

    The provision is displayed twice, i.e one in each report SA/IRB.

    May impact the computation of the report C04 in the computation of the IRB shortfall (line 0145)

    With CRR3, these cases will happened a lot more often, and not displaying (or displaying twice) the provisions doesn’t seems acceptable for us.

    Submission date
    06/03/2023
    Rejected publishing date
    29/09/2023
    Rationale for rejection

    This question has been rejected because it does not fulfil the formal criteria for submission. It was necessary to interpret the intention of the request, since the problem is not identified clearly. Also it does not include any question. 

    For further information on the purpose of this tool and on how to submit questions, please see 'Additional background and guidance for asking questions'.

    Status
    Rejected question

    Footer

    EUROPEAN BANKING AUTHORITY

    Our mission is to contribute to the stability and effectiveness of the European financial system through simple, consistent, transparent, fair regulation and supervision that benefits all EU citizens.


    UE logoAn agency of the EU

    EU Agencies Network logoEU Agencies Network

    EMAS logoSustainable EBA

    Contact us

    • Contacts
    • Ask a general question
    • Send a press query
    • Ask a regulatory question
    • File a complaint
    • Whistleblower reports

    Stay up to date with our work

    • Subscribe to our email alerts
    • News & press RSS feed

    Follow us on Social media

    • Bluesky
    • LinkedIn
    • X
    • YouTube

    Find out about us

    • The EBA at a glance
    • Vacancies
    • Privacy policy
    • Legal notice
    • Cookies policy
    • Frauds and scams

    Explore related sites

    • EIOPA
    • ESMA
    • ESRB
    • CEBS archive