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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

Corporate exposures in C10.00 memorandum lines r0250 and r0260

In template C10.00, institutions that apply the IRB approach, shall break down IRB exposures by SA exposure class. This template includes the following 2 memorandum lines: r0250 Corporates - F-IRB  r0260 Corporates - A-IRB How should 'Corporates' be interpreted for these two memorandum lines? Does that relate to the volume reported on rows r0100 (Corporates - other) and r0120 (corporates - specialised lending) of template c10.00? The ITS does not clarify this. Therefore the question is whether the sum of rows r0250 and r0260 should reconcile with the sum of C10.00 rows r0100 and r0120? An alternative interpretation is that the SUM of rows r0250 and r0260 should reconcile with the sum of corporate exposures reported in the C08.01 IRB template. We feel that this alternative interpretation is not logical as it would repeat numbers already (separately) reported in C08.01 and separately identifiable, both whether it relates to 'corporates' and whether it relates to A-IRB and F-IRB is identifiable via the Z-axis. Therefore we feel that this interpretation will not add any added value. Could you please clarify to which 'Corporates' lines r0250 and r0260 refer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

v6332 - Negative FV changes os hedged intems (C 32.01)

In relation to Q&A 2022_6511 where a question was raised related to validation rule v6566_s. We believe validation rule v6332_m should be deactivated for row 120.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Liability category of margins received

Could you please clarify if margins received, part of a repo or derivative netting agreement can always, regardless of whether the netting results in a net liability or asset position, be considered r0120 - Secured liabilities, or should be allocated to other liability categories as defined in Resolution Plans report Z02? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Requirements of Z 11.00 for RLE that are not institutions

Article 3 - Group resolution reporting  We observed some differences, especially for the Z 11.00 template when comparing the 2 parts of the final draft below: the draft proposal to the commission (chapter 3 Draft Implementing Technical Standards, article 3) and the tab in accompanying documents (chapter 2 Background and rationale - 2.2.4 Overview of revised reporting obligations). It seems there is no article requiring specifically from RLEs that are institutions to report Z 11.00 template, although it is included in the tab "Overview of revised reporting obligations". The Z 11.00 template is mentioned in paragraph 7, which seems to either concern the resolution entity or the scope of the article seems to be (too) large (all entities?). Could you please confirm whether Z11.00 template is required for RLE that are not institutions? Other information: In order to compare with Z02.00 requirements, paragraph 3 (a) specifically required Z 02.00 for RLE that are institutions.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Calculation rule

Please precise calculation rules for : number of transactions on proprietary accounts (column 0100) number of transactions on clients accounts (column 0110) Cumulated notional amount  (column 0140)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Provide a detailed definition of the 'operator' of the FMI.

Please provide a detailed definition of the 'operator' of the FMI, and some examples.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Onboarding capacity - Number of applications from new customers over 1 working day

If the bank has a central team managing all account openings within the group, with colleagues assigned to a specific Member State. E.g. two colleagues are dedicated to opening accounts in Luxembourg, how should we clarify the “Onboarding Capacity”, which is defined as the highest number of applications where the institution has validated the request for a bank service? We seek guidance on which of the following approaches would be most relevant: Real statistics-based calculation: if the average daily number of new accounts opened in Luxembourg is 1 (handled by 2 colleagues in the central team), should the onboarding capacity be reported as 1? And if it takes 15 days to onboard new client (handled by 1 colleague or 2 colleagues in the central team)  in Luxembourg then should we report 0 or 0.1 (1 application /10 days)? Full Central Team Capacity (Single Country): if the entire central team were assigned exclusively to Luxembourg, the average daily onboarding capacity could increase to 5. Should this theoretical highest number of 5 be considered for Luxembourg ? Kindly note that in the capacity of the capacity for every other country would be zero as a consequence. How then to report for the remaining countries? Full Central Team + Project Support (Single Country): If the central team had the additional project support (e.g. temporary resources), the average daily capacity for Luxembourg could reach a higher level, e.g. 50. Should such scenarios be considered for “Onboarding Capacity”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Instructions to follow regarding new EBA Resolution Reporting

For the sake of clarity, the Bank reports below an example for the “Value of positions on proprietary and client accounts” of the difference between the two instructions 1.      SRB Guidance on FMIR: […] Daily average value at end of settlement day over the previous year. If not available, daily average value over a shorter time period and c0140 and c0150 should be filled. To calculate daily averages, please use the opening days of reported FMIs. If not available, you may use the TARGET2 opening days as a proxy. Total values should be included, not only values of relevant currencies as reported in c0120-c0170 2.      EBA Instructions on New Resolution Reporting – Z09.03: […] Average value at end of settlement day over the previous year.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Guidance for credit institutions on which countries fall under scope of the Critical Function Report (CFR)

We currently do not see any indication for country-specific information. Will the EBA provide requirements on which countries are to be covered for each Critical Function Report?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Taxonmy 3.5 - Inconsistant Validation rules

Relating to daisy chain deduction on M 03.00 report, 3 validations rules are inconsistent together (v10839_s, v22357_s and v22545_m)    

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL

Large Exposures Reporting: Labelling of transactions where there is an exposure to underlying assets

When reporting exposures through transactions where there is an exposure to underlying assets (Article 390(7) of CRR) in the large exposures templates (LE2 and LE3), shall the value “Yes” be reported in column 030 only for the additional exposure stemming from the structure of the transaction, or shall the value “Yes” be reported in column 030 for the exposures stemming from the underlying assets as well?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Reporting of Crypto Assets (C36.00 Template) - Risk Type Coverage

With regards to the reporting of information relating to the Crypto Assets (C36.00 Template), we are required to report a) Crypto-asset exposures to tokenised traditional assets; b) Exposures to asset referenced tokens and c) Exposures to other crypto assets. In terms of scope, should this include both Credit and Market Risk positions OR just Credit Risk?

  • 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)

Clarifications about the new column 65 “Offsetting Group” in template C06 under DPM 4.0

Should column 65 (Offsetting Group) in template C06 be reported in 202506?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

COREP C22.00 reporting of positions in the reporting currency

Can EBA provide some examples of cases where positions in the reporting currency contribute to the calculation of the capital requirements according to Article 354 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Domestic sovereign debt

EBA Q&A 2023_6737 states "Exposures shall be deemed to be domestic where they are exposures to counterparties located in the Member State where the institution is established". Could we confirm that this is also valid in context of the currency of denomination of the debt? e.g. if an EU government issued debt in a currency other than its domestic currency - e.g. Romanian government issues EUR debt instead of RON debt would this still be deemed to be "domestic sovereign debt"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

COREP CVA Risk reporting – exempted CCP-related transactions

In case of an institution that is also a clearing member to a QCCPs, for its CCP-related transactions that are exempted from CVA own funds requirements under CRR article 382(3), should these be reintegrated/reported in COREP template C25.01 row 0050?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

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

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

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

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

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