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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.

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List of Q&A's

Corep reporting C 34.06 – Top 20 counterparties - validation rule EBA_v10236

Concerning the Corep reporting C 34.06 – Top 20 counterparties, further clarification is required for validation rule EBA_v10236.Row 0040 (Sector of the counterparty) specifies that one sector must be chosen for each counterparty based on the following FINREP economic sector classifications: (i) x10 Central Banks ; (ii) x1 General Governments; (iii) x12 Credit institutions; (iv) x599 Investment firms as defined in Article 4(1), point (2) of Regulation (EU) No 575/2013; (v) x598 Other financial corporations (excluding investment firms); (vi) x20 Non-financial corporations.However, some counterparties in our EQ options are individuals (households) and do not fall under any of the codes allowed . How to meet the requirements of validation rule EBA_v10236 for the household sector among the 20 largest exposures due to counterparty credit risk?which of the values ('x10', 'x1', 'x12', 'x598', 'x599', 'x20') should be used for physical persons as reporting 'x5-households'  defined in CT16_1 is not permitted?or maybe households are not in a scope of reporting and should be excluded from the table?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements

Admissible values to {C34.06, c0040}

According to XBRL rule v10236_a: [C 34.06 (All rows)] {C 34.06, c0040} in {[eba_CT:x10], [eba_CT:x1], [eba_CT:x12], [eba_CT:x598], [eba_CT:x599], [eba_CT:x20]}. On the other hand, "DPM table layout and Datapoint categorization" file available at EBA website, the admissible values are: (CT:x10) Central banks; (CT:x1) General governments;  (CT:x12) Credit institutions;  (CT:x18) Financial corporations other than credit institutions; (CT:x598) Financial corporations other than credit institutions and investment firms; (CT:x599) Investment firms; (CT:x20) Non-financial corporations; (CT:x5) Households.  The EBA xbrl validation rule does not include (CT:x18) "Financial corporations other than credit institutions" nor (CT:x5) "Households". This mismatch has been caused validations warnings. Could you, please, clarify which admissible values should be considered for {C34.06,c0040} ?

  • 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

Interaction between Qualified CCPs and Reporting C 07.00/C 08.00

Where should institutions report the values of all its trade exposures with QCCP? 

  • 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)

Sovereign credit assessment to apply to exposure of central government, central bank and government-100%-owned central bank.

1. Is sovereign credit assessment of a country by a nominated ECAI available for assigning a corresponding risk weight to exposures to the central government or central bank of this country? 2. Is sovereign or central government credit assessment applicable to central bank when a central bank is 100% owned by central government?

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

Automatic cancellation of commitments qualified as unconditionally cancellable commitments (UCC)

If contractual arrangements of a commitment provide for automatic cancellation due to deterioration in a borrower’s creditworthiness, but the cancellation is not always automatic considering client relationship, can this commitment be considered as an unconditionally cancellable commitment (UCC)?

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

Clarification on EBA provisions for treatment of Non-Stable and Non-Core NMDs in SOT on NII.

Can banks, in their internal measurement methodologies for calculating the NII SOT baseline scenario, for renewed Non-Stable/Non-Core NMDs assume repricing at the current market interest rate without any commercial margin, in order to avoid stabilisation of NII on unstable funds? Is this approach in line with EBA/GL/2022/14 and permitted under EBA/RTS/2022/10?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities

Reporting of marginal deposit facility amounts (overnight deposits with the central bank) in templates C72 and C74.

It is not clear how the amounts in Central Banks regarding the marginal deposit facility should be treated in the calculation of the LCR and reported in C72 and C74.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

New EBA Validation rules taxonomy 3.2 in C.14.00 CR SEC Details v7364_m consistency

The information declared in template C13.01 does not exclude the possibility of holding positions in corporate loans for synthetic senior STS securitisations.  However, control v7364_m on template C14.00 restricts the scope of application to SME loan portfolios. Can you change the formula for this control to include corporate portfolios?

  • 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

Validation rule v7364_m - Securitisation Template C 14.00

Should validation rule v7364_m take into account other eligible asset types for the underlying pool of exposures?

  • 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

Validation rule v11873_m - Securitization Template C 14.00

Should validation rule v11873_m be amended for securitisation programs under an active replenishment period?

  • 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

C14.00 - v11661_m - Attachment and Detachment points

The EBA Validation Rule v11661_m states that: For all securitization programs (on-balance or off-balance) the attachment point (AP) of the senior tranche must be higher than the detachment point (DP) of the first loss tranche. Should this control be applicable? 

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

Validation rule v11873_m

The formula of EBA validation rule v11873_m is the following: {C 14.00, c0230} + {C 14.00, c0240} + {C 14.00, c0250} <= {C 14.00, c0140} This rule is activated in DPM 3.2 for template C 14.00, and states that the total amount of securitized exposures should be equal to or lower than the amount of notes issued in the senior/mezzanine/first loss tranches. However, depending on the characteristics of the securitization structure and the timing of the notes payments date, the amount of securitized exposures can be either higher or lower than the amount of notes issued.

  • 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

Requirement for loan agents to register as payment service providers under EU's Second Payment Services Directive 2015/2366 ("PSD2").

I would like some clarification on Directive 2015/2366/EU (PSD2) Article 4 paragraphh 22 - Money remittance. If a firm performs administrative services (including but not limited to the calculation of interest/fees and principal owing between lenders and a borrower) and as part of this service is required to regularly transfer money between lenders and a borrower (no fee involved), does this qualify as money remittance? No fees are charged for the transfer of money.  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

The SCA-Exemption for account access based on art. 10 of Regulation (EU) 2018/389 as amended by Regulation (EU) 2022/2360.

We require a clarification with reference to the art. 10 of Regulation (EU) 2018/389 as amended by Regulation (EU) 2022/2360, regarding the meaning of the sentence: “…provided that access is limited to one of the following items online…”.  Does it mean that the 180days exemption is not allowed in case the PSU requires at the same time and in the same request: i) balance and ii) transactions-list of her/his payment account?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Template 3, Climate Change Alignment Metrics

Regarding the data requirement, should all companies falling under the NACE codes defined in Template 3 be included, or can practicality be applied to specifically target companies for whom the transition risk metric is relevant?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 2 - Energy efficiency of the collateral without EPC label

Could you please clarify the objective of columns o and p in rows 5 and 10 as EPC label cannot be estimated and the total is already reported in column a?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 3, Climate Change Alignment Metrics

Does IEA NZE 2050 explicitly provide alignment metrics, including intensity targets for every relevant sector? Furthermore, are these applicable metrics listed, documented and accessible somewhere? If a metric can be determined from IEA NZE 2050, would one metric be adequate per sector?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Can Taxonomy eligible but not aligned exposure be included into template 10 “Other climate change mitigating actions that are not covered in the EU Taxonomy”

Question 1: Should this template include ONLY exposure NOT eligible in the EU Taxonomy? OR can exposure eligible in the EU Taxonomy but not aligned be reported as well?   Question 2: supposed the answer for question 1 is: exposure eligible in the EU Taxonomy but not aligned can reported in template 10, can we derive that such exposure will be reported in both the GAR (because eligible and not aligned) and in the template 10?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Pillar 3 reporting obligations

Within the Pillar III disclosures, there are specific sectors that have a handful of dominant companies (3 or less) where the financial institutions have to disclose data for these specific NACEs separately. Would the above Eurostat-confidentiality rules stand within the Pillar III disclosures?

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

Remuneration policy disclosure regarding Management Bodies of subsidiaries of an EU parent institution

We would appreciate the EBA to shed light on the disclosure requirements about remuneration for EU parent institutions for the purpose of the Pillar 3 Disclosure Report and under Annex XXXIV of the Commission Implementing Regulation (EU) 2021/637. Indeed, requirements under the Annex stipulate that information on members of the Management Body disclosed under “Template EU REM1 – Remuneration awarded for the financial year” shall, in accordance with Article 13 CRR, be disclosed on the basis of their consolidated situation. In such case, the disclosure entity will solely reflect, in the columns related to Management Body, information on their own management body while information on the identified staff of the management bodies of subsidiaries shall be disclosed under the relevant business area. We would kindly ask for detailed explanations on how EU parent institutions shall disclose the Management Body members of their subsidiaries in terms of columns within “Template EU REM1 – Remuneration awarded for the financial year” (i.e., under column a/b, c or d) and “Template EU REM5 – Information of staff whose professional activities have a material impact on institutions’ risk profile (identified staff)”.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR