Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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

Asset amount deducted - Tier 1 capital (Derivatives Cash Flow Hedge)

Derivatives positions can be an Asset or a Liability depending on market situations, while their related CF hedge amount is always a Credit/Debit amount booked on Equity level, thus the CF hedge reserve does not fully match an asset in the leverage ratio. Shall we always deduct the cash flow hedging reserve in Leverage Ratio calculation?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Traetment of precious metals

Could precious metals, such as gold, silver etc., be considered as HLQA, i.e. be included in the LCR buffer? Otherwise, could be precious metas be considered in C66 Counterbalancing Capacity in the residual row "Other tradable assets"?

  • 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

Secured central bank lending and liquidity buffer adjustment

How to approach unwinding mechanism according to Article 17 (2) of Commission Delegated Regulation (EU) 2015/61 in case institution uses retained covered bonds as a collateral for securities financing transaction where counterparty is domestic central bank?

  • 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

Reserves held by the credit institution in a central bank

How to report a negative eligible withdrawable amount in LCR template 72 row 050 ID 1.1.1.2. Item Withdrawable central bank reserves Amount/Market value column 010. For example Central bank balance:                                1,659,504 Minimum reserve:                                      2,323,727 Total withdrawable central bank reserve:     - 664,224   There are two EBA validition rule which indicates that withdrawable central bank reserves Amount/Market value should be >= 0. EBA v7683_s. : [C 72.00.a (All rows, c0010)] {C 72.00.a} >= 0. EBA v7681_s: : [C 72.00. r0010;0020;0030;0040;0050;0060;0070;0080;0090;0100;0110;0120;0130;0140;0150;0160;0170;0180;0190;0200;0210;0220;0230;0240;0250;0260;0270;0280;0290;0300;0310;0320;0330;0340;0350;0360;0370;0380;0390;0400;0410;0420;0430;0440;0450;0460;0470, c0040)] {C 72.00.a} >= 0

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

Inclusion of products accounted at fair value in the net interest income

Should products accounted at fair value be included in the net interest income measure plus market value change when the fair value of the product is based on expert say and is therefore independent of the level of interest rates ?

  • 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

General Prior Permission (GPP) to call, redeem, repay or repurchase eligible liabilities pursuant to Article 78a(1) second subparagraph of the CRR .

Can the resolution authority allow - under specific conditions - institutions, to which a GPP has been granted, to consider the issuance of new eligible liabilities instruments during the authorization period for the purpose of calculating the unused part of the predetermined amount?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions

Net interest income measure plus market value changes

Could you please confirm that fair value variations of financial products accounted at amortised cost (as the management intention is to hold them until maturity) are not to be accounted for the net interest income measure plus market value changes ?

  • 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

Identification of counterparty

The treatment of client exposures to a CCP via a clearing member is described in art 305 and consists of 1/ application of art 305 paragraph 1 (when the conditions in paragraph 2 are not met) = use of counterpart credit risk section 1 to 8 for the CCP-related transactions with the clearing member 2/ application of art 305 paragraph 2 (and subject to paragraph 3) = use of art 306 for the trade exposures with the CCP Can it be clarrified which party should be treated as the counterparty in sush a transaction (the clearing member or the CCP) under Corep? Can it in addition be clarrified whether the same counterparty as in Corep should be used under Finrep?    

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

Net interest income measure plus market value changes

Should Mutual Funds which capitalise interests (no payment of interest and accounted at fair value) be taken into account for the net interest income measure plus market value changes ?

  • 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

Net interest income measure plus market value changes

Should products accounted at fair value be included in the net interest income measure plus market value change when the fair value of the product is based on expert say and is therefore independent of the level of interest rates ?

  • 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

Perimeter of CSRBB

Should such investment products (such as bonds) accounted at amortised cost be included in the CSRBB perimeter when the management intention is to hold the asset until maturity?

  • 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

EBA validation rules v3900_s and v5693_s

Should the severity of EBA validation rules v3900_s  and v5693_s be changed from ‘non-blocking’ to ‘warning’ to allow for the possibility of negative interest income values?

  • 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

FINREP template F44.03, F44.04

In template  44.3  Staff expenses by type of benefits  in row 0010 “Pension and similar expenses” are requested. In template 44.4 Staff expenses by category of remuneration and category of staff in row 0030 “Staff expenses other than remuneration” are requested.  For the whole template the following validation rules applies: v3988_s: {F 44.03} >= 0 (for all rows and with severity level error); v8364_s ({F 44.04} >= 0). This is suggesting Pension and similar expenses  and Staff expenses other than remuneration  can never be a negative amount, which we believe is not always the case (as a result of changes in the fair value of the liability recognised). Can you please amend the Validation rules by excluding row 0010 (44.3 Template), row 0020 ((44.4 Template) from those rules?

  • 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

Finrep Templates 44.03 and 44.04

In template 44.3 Staff expenses by type of benefits , in row 0050 Severance payments are requested. For the whole template the following validation rule applies: v3988_s: {F 44.03} >= 0 (for all rows and with severity level error). This is suggesting severance payments can never be a negative amount, which we believe is not always the case (as a result of reviewing HR restructuring provisions as well as discounting effects of long term employee benefits. The same applies for template 44.04 other staff expense except remuneration (r0030 / c0010), where the amounts reported in 44.3 r0050/c0010 are reported, too. A positive amount reported in this item leads to the violation of the rules v8106_m and  v8364_s. Can you please amend the Validation rule by excluding the items 44.3 r0050/c0010 and 44.4 r0030/c0010 from these rules?

  • 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 eba_v0315_m working incorrectly in C07 templates in a column 0216 for derivatives

Could validation rule eba_v0315_m be modified for a column 0216? At the moment it does not work in situations when there are derivative exposures with SME supporting factor in a row 0110 but not in an of which row 0120.

  • 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

Annex XI - Leverage (template C43)

It is not clear from the instructions what exposure amount is expected to be reported for items deducted from capital in the columns dedicated to RWEAs in C43.

  • 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

Clarification on reporting of “Total Assets” within C40.00 {0410;0010}, as defined in Annex XI.

Annex XI defines {C40.00, r0410, c0010} as “the total assets following the scope used in the published financial statements.” Having regard to the meaning of the word “published” used within this context, please confirm whether the total assets to be reported in C 40.oo must necessarily be equivalent to the total assets disclosed in the latest interim or year-end published financial statements. If in the affirmative, this would imply that, for institutions with only semi-annual and year-end publication dates (as opposed to quarterly publications), {C 40.00, r0410, c0010} shall not be updated within two quarters during a calendar year, given that such figure would be held constant as per latest publication. If this treatment is confirmed, our question further extends to the intended reporting of constituent rows, such as C 40.00 r0010, c0010} and {C 40.00, r0090, c0010}. We understand that the scope of reporting shall be consistent across the entire template, therefore for such rows, we would like to confirm whether they shall also be kept constant as per latest published financial statements, given the lack of instruction to these specific rows.

  • 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

Withdrawable Central Bank Reserves in ALMM C 66.01 when considered Liquid Assets

Where should withdrawable Central Bank Reserves that are considered Liquid Assets according to Regulation (EU) 2015/61 be allocated in ALMM C 66.01 Maturity Ladder?

  • 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

Treatment of amortization and interest flows - received within 30 days - from securities

ANNEX XXV REPORTING ON LIQUIDITY (PART 3: INFLOWS) clarifies the treatment of inflows from securities maturing within 30 days Row 190, ID 1.1.5. What is the correct treatment of amortizable securities for which capital repayments occur within 30 calendar days ? What is the LCR treatment of interest inflows from securities that occur within LCR horizon ? 

  • 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

Interpretation of the appropriate estimator for Credit Conversion Factors (CCF)

Is it possible to interpret the concept of “default weighted average from all observed defaults” as described for realised CCFs in article 182 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 as “the arithmetic average of the yearly averages”?

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