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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

Taxonomy 4.0: The validation rules v7538_m and v7546_m perform consistent cross-checks?

In terms of Implementing Technical Standards (ITS), when checking the rules of the COREP_OF module for Tables C_08.01.a, C_08.02, C_09.02 have been detected inconsistencies in the validation rules under template C09.02 cross check part. It’s possible to verify this?

  • 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 framework 4.0 Validation rules

Could you please confirm whether validation rule v23722_m is incorrect and should be amended, as it only counts time buckets greater than 7 years, which appears inconsistent with the ITS requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Reporting framework 4.0 Validation rules release (new format) (Uploaded on 19/12/2024)

Could you please confirm whether validation rule e4900_n is incorrect and should be amended by removing r0190 from the rule and validation rule v0313_m is incorrect and should be amended by adding r0210 to the rule?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Validation rules taxonomy V4.0 C_08.01.a,C_09.02 - v1672_m

The validation rule formula v1672_m specifies that the Risk Weighted Assets (RWA) after supporting factor in column 0125 reported under form 09.02 for IRB exposure class corporates – purchased receivables of all country should be equal to RWA reported under form C_08.01.a, column 0260 where Sheet is in qAE:qx2075 (Corporates - Purchased receivables with own estimates of LGD or conversion factors). The Sheet qAE:qx2076 (Corporates - Purchased receivables without own estimates of LGD or conversion factors) should also be considered in the formula for comparison of exposure to corporates – purchased receivables (with and with-out own estimates of LGD or conversion factors). This Sheet qAE:qx2076 is also a part of validation rules v0435_m, v0436_m and v0438_m where a similar comparison is made for original exposure, Exposure at Default (EAD) and RWA pre supporting factor. The control seems incoherent. Can you please confirm the sheets which need to be included for comparison of corporates – purchased receivables between forms C_08.01.a and C_09.02?

  • 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 rules taxonomy V4.0 C_08.01.a,C_09.02 - v0418_m

The validation rule formula v0418_m specifies that the Risk Weighted Assets (RWA) reported under form 09.02 for IRB exposure class central governments and central banks of all country should be less than or equal to RWA reported under form C_08.01.a, column 0255 where Sheets are in qAE:qx2021 (Central governments and central banks with own estimates of LGD and/or conversion factors), qAE:qx2020 (Central governments and central banks without own estimates of LGD or conversion factors), qAE:qx2014 (Corporates - Specialised Lending without own estimates of LGD or conversion factors), qAE:qx2055 (Retail exposures - Purchased receivables - with own estimates of LGD or conversion factors). The Sheet qAE:qx2014 and qAE:qx2055 should not be considered in the formula for comparison of exposure to central government and central bank. These two sheet’s codes are also not part of validation rule v0415_m and v0416_m where the similar comparison is made for original exposure and Exposure at Default (EAD). The control seems incoherent.

  • 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

Application of formulae v23061_m on r0180

Could you please confirm that the formulae v23061_m needs to be modified and should apply to all rows except r0180?

  • 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

currencies Lithuanian Litas and Croatian Kuna

In C 22.01 the currencies Lithuanian Litas and Croatian Kuna are still available in the Annotated templates, while removed from C_2024_8389_1_ANNEX_EN_V3_P1_3682615.XLSX, which was published after the Annotated templates. Can we assume these 2 currencies should be removed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

v7364_m

Is v7364_m complying with the 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

Calculation of the Countercyclical Capital Buffer

Clarification  to EBA Q&A 2016_3050 and CRM techniques with substitution effects How do we have to consider CRM techniques with substitution effects on the exposure in the CCB?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

v4769_m and v4770_m rules

We inform you that the v4769_m and v4770_m rules of the EBA 4.0 taxonomy, which verify that the “TOTAL” exposure class is equal to the sum of the exposure subclasses, are incorrect because the “Memo item” exposure classes of the C_08.01 report are wrongly included in the sum.

  • 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_OF, C_10.00, modelling on columns c0090 and c0100

How shall institutions report information in COREP_OF, table C.10.00, columns c0090 and c0100?

  • 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 rules taxonomy V4.0 C10.00 v23057_m

Does formulae v23057_m should apply to all columns?

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

Validation rules taxonomy V4.0 C10.00 v23055_m

Does formulae v23055_m should apply on all columns?

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

Validation rules taxonomy V4.0 C10.00 v23054_m

According to the formulae v23054_h : {r0150} >= {r0151} in C10.00.This control indicates that the row r0150 “Secured by mortgages on immovable property and ADC exposures” must be superior to row r0151 “  Of which: Exposures secured by mortgages on residential property up to 55% of the property value” on all report rows.However, the formula of control v23086_m indicates that only row r151 must be reported on memo item column c0090 "EXPOSURES SECURED BY MORTGAGES ON RESIDENTIAL PROPERTY UP TO 55% OF THE PROPERTY VALUE" so the first control cannot be compliant as row r150 must be empty. This also applies to rows r150 and r151 on memo item columns c0100, c0110 and c0120 as formulae v23087_m and v23088_m indicate that, respectively, only rows r0152 and r0101 should be reported on, respectively, columns c0100 and c0110.Could you please therefore confirm that the control v23054_m needs to be modified and should apply to all columns except memo items columns?

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

COREP_OF, C_07.00, problem with disallowed risk weight 70%

Why are cells r0210-c0010, r0210-c0030, and r0210-c0040 (Risk Weight 70%) in table C_07.00 disallowed despite CRR3 Article 126 allowing a 70% risk weight for certain exposures (ETV ≤ 60%)?

  • 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_OF, C_07.00, problem with disallowed risk weight 70%

Why are cells r0210-c0010, r0210-c0030, and r0210-c0040 (Risk Weight 70%) in table C_07.00 disallowed despite CRR3 Article 126 allowing a 70% risk weight for certain exposures (ETV ≤ 60%)?

  • 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

NACE 2025 reporting in ITS

The upcoming changes to the NACE (Nomenclature of Economic Activities) codes in 2025 are going to have certain implications for banks, particularly in relation to the ITS on supervisory reporting of institutions. For bank supervisory reports in 2025 in which data on NACE activity are requested, should the applicable NACE classification be based on the current NACE classification, or should the NACE activity codes be based on the NACE 2025 (which will be officially enacted on 1 January 2025)?

  • 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)

SME

In the instructions for Finrep ITS consolidated - Annex V to EU Regulation 2021/451 - there is a definition of SME in point 5.i ‘SME’: micro, small and medium-sized enterprises as defined in Commission Recommendation C(2003)1422 (6); (Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises (C(2003)1422) (OJ L 124, 20/05/2003, p. 36), where in article 1: “Enterprise An enterprise is considered to be any entity engaged in an economic activity, irrespective of its legal form. This includes, in particular, self-employed persons and family businesses engaged in craft or other activities, and partnerships or associations regularly engaged in an economic activity.” In accordance with the above-mentioned recommendation and SME definition, the scope  of enterprises also includes self-employed individuals. Given that SME are reported in FINREP ITS as enterprises,  should self-employed entrepreneurs be treated as enterprises as well?  

  • 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)

Calculation of minimum lease payments in case of operational lease

Does the EBA acknowledge that the residual value should be discounted, or the interests on this residual value should be filtered out of the calculation of the discounted minimum lease payments, to avoid an increase of the exposure beyond the accounting value?

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

Internal Model Method

What is the prudential treatment of cash flow spikes in the calculation of own funds requirements for counterparty credit risk under the Internal Model Method?

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