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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

FICOD Inconsistency between ITS and Taxonomy

Dear all,    I'm contacting you as we are working in the implentation of FICOD DPM 4.2 framework and we have some difficulties to understand the technical expectations regardings : L_0100 : column 0101 L_0200 : column 0101 L_0200 : column 0201 Those three cells seem to point on a list of closed options called [ZZ:ZZ94], which can take : x840 banking sector x841 insurance sector x842 investments services sector x843 other undertaking of the group We do not understand this modelisation as for us those columns should be pointing on the following values : ype of ID code used for the ‘ID code of the instrument’ item. One of the options in the following closed list of codes shall be used: 1 - ISO 6166 for ISIN code 2 - CUSIP (the Committee on Uniform Securities Identification Procedures number allocated by the CUSIP Service Bureau for United States and Canadian companies) 3 - SEDOL (Stock Exchange Daily Official List for the London Stock Exchange) 4 - WKN (Wertpapier-Kennnummer, the alphanumeric German identification number) 5 - Bloomberg Ticker (Bloomberg letters code that identifies a company’s securities) 6 - BBGID (the Bloomberg Global ID) 7 - Reuters RIC (Reuters instrument code) 8 - FIGI (Financial Instrument Global Identifier) 9 - other code provided by members of the Association of National Numbering Agencies 99 – A code allocated by the undertaking Please refers to the ITS : Implementing regulation - 2022/2454 - EN - EUR-Lex We do not understand the expections from EBA and we strongly think that the value published on those cells does not refer to the correct choice list. Could you please advises us on a workaound?

  • Legal act: Directive 2002/87/EC (FiCOD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification on reporting of columns 0050–0100 in template J 09.02b (EGDQ_0902b) – delta cashflows vs repricing dates

Could the EBA please confirm the supervisory expectation regarding the correct population of columns 0050–0100 in template J 09.02b? Specifically, should these columns be reported as:(a) delta cashflows / changes relative to the baseline, consistent with the reference to J 01.00 r0040; or (b) repricing dates (in years) of deposits under each of the six SOT scenarios, consistent with the validation rules applied? If repricing dates are intended, we would appreciate clarification on how this aligns with the explicit reference to J 01.00 r0040 and the definition of “Δ EVE” in the ITS.

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

Are the validation rules v10667_m, v4769_m, v4772_m, v903250_h correct?

The  validation rules v10667_m, v4769_m, v4772_m, v903250_h included in DPM 4.2 appear incorrect. v10667_m: The rule requires that the exposure-weighted maturity values (c0250) multiplied by Exposure value (c0110) in templates c08.01 and c08.02 are equal. However, as the Maturity is required to be rounded to full days and cannot be delivered with decimals, the rule cannot be met as the rounding will cause a difference between the templates. v4769_m: The rule requires that the total of all exposure classes equals the sum of the exposure classes for template C08.01. However it is incorrectly applied to columns that contain exposure-weighted non-monetary values (c0230-0240: %s, c0250: days), which cannot be aggregated. v903250_h: The rule requires that the absolute value of r0010 is greater that sum of  absolute values on rows r0015 and r0016 in template C08.01. However it is incorrectly applied to columns that contain exposure-weighted non-monetary values (c0230-0240: %s, c0250: days), which cannot be aggregated. v4772_m: The rule requires that the Expected Loss amount (c0280) is smaller than the Original Exposure Value (c0020). This rule appears incorrect as the c280 is reported after substitution effects CRM, where are c0020 is reported prior to substitution effects due to CRM.  

  • 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

Validation rule v903627_h

Is the validation rule v903627_h consistent ? Indeed an equality is expected between row Corporates {r0030} and the sum of rows SME {r0050} and Large Corporates {r0051} which is not possible as it doesn't take into account the whole corporates scope.

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

Incoherent formulae on the validation rule v4769_m

Should the validation rule v4769_m apply to columns 0230, 0240, and 0250 of report C08.01?

  • 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

C.08.01 - VariableVID 3293070 - Identical cells

Should the identical cell rule with VariableVID equal to 3293070 be applicable to C08.01?

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

Incoherent formulae on the validation rule v0476_m

Should the validation rule v0476_m be active?

  • 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

Incoherent formulae on the validation rule v0471_m

Should the validation rule v0471_m be active?

  • 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

Incoherent formulae on the validation rule v0473_m

Should the validation rule v0473_m be active?

  • 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

Incoherent formulae on the validation rule v0475_m

Should the validation rule v0475_m be active?

  • 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

Incoherent formulae of the validation rule v1674_m

Should the validation rule v1674_m be active?

  • 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

Incoherent formulae of the validation rule v4786_m

Should the validation rule v4786_m be active?

  • 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

Validity of validation rule v903627

The rule v903627 seems incorrect. with{tC_09.02, (c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0121, c0122, c0125, c0130), default: 0, interval: true}: {r0030} = {r0050} + {r0051} Rows r0050 and r0051 are not a full breakdown of r0030. Non SME and Non Large Corporate exposures are also included within this scope.  0030 Corporates 0050 Of Which: SME 0051 Of Which: Large Corporates  

  • 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

Validity of validation rule v903610

The validation rule v903610 seems invalid.   with{tC_34.03, c0030-0070, s*, default: 0, interval: true}: {r0010} = {r0190} + {r0230} + {r0120} + {r0050} + {r0270} + {r0340} Since transactions may be categorized in multiple risk categories, summing per risk category will double count those transactions.  

  • 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

Validity of validation rule v903250

This validation rule seems invalid. with{tC_08.01.a, (c0020, c0030, c0040, c0050, c0060, c0070, c0080, c0090, c0101, c0102, c0103, c0104, c0105, c0106, c0107, c0110, c0140, c0150, c0160, c0170, c0171, c0172, c0173, c0180, c0190, c0200, c0210, c0250, c0255, c0256, c0257, c0260, c0270, c0280, c0290, c0300), default: 0, interval: true}: abs({r0010}) >= abs({r0015}) + abs({r0016}) For column c0250 this formula is not valid. r0015 and r0016 are different subsets of r0010 but not 'complete', other exposure not falling into the subsets may exist as well. This can determine the average maturity of r0010 so that the condition is not true.  

  • 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

Validity of validation rule v4769_m

The v4769 validation rule seems invalid. with {tC_08.01.a, c0020-0290, default: 0, interval: true}: {r0010} [where qEEA=[eba_qAE:qx2023]] = {r0010} [where qEEA=[eba_qAE:qx2021]] + {r0010} [where  qEEA=[eba_qAE:qx2071]] + {r0010} [where qEEA=[eba_qAE:qx2073]] + {r0010} [where qEEA=[eba_qAE:qx2015]] + {r0010} [where qEEA=[eba_qAE:qx2075]] + {r0010} [where qEEA=[eba_qAE:qx2013]] + {r0010} [where qEEA=[eba_qAE:qx2068]] + {r0010} [where qEEA=[eba_qAE:qx2009]] + {r0010} [where qEEA=[eba_qAE:qx2055]] + {r0010} [where qEEA=[eba_qAE:qx2081]] For columns which are calculated as a weighted average, a summation is not correct.  

  • 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

Validation v903251_h in relation to EBA Q&A 2020_5551

EBA Q&A 2020_5551 confirmed that the SME support factor and Infrastructure support factor can be applied simultaneously. After applying this, we run into validation v903251_h which enforces the following: with{tC_07.00.a, c0010-0220, default: 0, interval: true}: abs({r0010}) >= abs({r0030}) + abs({r0035}) This validation enforces that the exposure reported on row r0010 of C07.00 is larger or equal to the sum of r0030 (exposures subject to SME-supporting factor) and r0035 (exposures to infrastructure projects supporting factor). This is not logical when the SME support factor and Infrastructure support factor can be applied simultaneously. Can you please review v903251?

  • 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

C10.00 - EBA VR v23089_m

The EBA Validation Rule v23089_m applicable to the C10.00 template states that the column 120 (IRB EXPOSURES SUBJECT TO COUNTERPARTY CREDIT RISK UNDER THE IMM) must be empty for all the rows except the rows 30 (SA exposure classes excluding securitisation positions) and 270 (SA exposures subject to counterparty credit risk under the IMM).

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

C09.02 - EBA VR v4786_m

The EBA Validation Rule v4786_m  states that EAD (c0105) should systematically be greater or equal to the RWA pre supporting factor (c0110) concerning the C09.02 template.

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

C08.01 - EBA VR v09774_m

The EBA Validation Rule v09774_m applicable to the C08.01 and C.08.03 COREP templates states that the total of the Exposure value concerning credit risk in C.08.01 (column 110: row 10 - row 40 - row 50 - row 60 - row 80) must be equal to the total of the Exposure value post conversion factors and post CRM in C.08.03 (sum of all rows of the column 40).

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