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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Scope for probation period

Paragraph 176 defines the criteria to discontinue forbearance classification. According to paragraph 176 (b) "...a minimum 2 year probation period has passed from the date the forborne exposure was considered as performing". According to Annex II “EBA ITS 2013 03 Annex I (Annex I ITS FBE NPE Amemdments Annex III ITS reporting IFRS templates)” paragraph 176 (b) is only applicable to table 19 column 50 (of which: Performing forborne exposures under probation). Does this mean that the 2 year probation period is only required for exposures which are reported in column 50 – i.e. exposures with forbearance measures which have been reclassified out of the non-performing forborne exposure columns (see paragraph 180)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_878
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/03/2015

Clarification of EBA answer published for Q&A 2014_1000

Q&A 2014_1000 states that there are only two accepted ways in FINREP to report interest income and expenses from financial instruments held for trading, interest income and expenses (“clean price”) or as part of the gains and losses from these assets (“dirty price”), and that for economic hedge there is the possibility to report the amounts separately as financial income or expenses.How should this answer be understood in the case of credit institutions applying “dirty price convention”? The possibility to report the amounts separately as interest income or expenses (mentioned in the last sentence of the answer) envisages only the items “Interest income. Financial assets held for trading” and “Interest expenses. Financial liabilities held for trading”?

  • 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)
  • ID: 2015_1878
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/03/2015

Inclusion of consolidated current and year-end profits in Common Equity Tier 1 Capital

According to Articles 18 and 19 of Regulation (EU) No 575/2013 (CRR), institutions have to carry out a prudential consolidation. The scope of entities included in prudential consolidation can differ from the scope of full financial consolidation. For the purposes of meeting the requirements of Article 26(2) of the CRR, should the current as well as year-end profits resulting from the prudential consolidation also be verified by persons independent of the institution that are responsible for the auditing of the accounts of that institution? Is the General Meeting of Shareholders obliged to confirm the year-end profit for the Group prudentially consolidated, in addition to the year-end profit for the Group financially consolidated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1221
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 20/03/2015

Validation rule v1384_m

With reference to Question ID 2013_345. Here you defined that the accounting of the impact of foreign currency translation (gain or loss) is included in row 190 ("Other Increase or Decrease in equity") and in column 050 ("Accumulated other comprehensive income"). Validation rule v1384_m defines that: sum({F 46.00, r200, ({c050}, {c100})}) is on par with {F 03.00, r360,c010}. One part of F 03.00, r360, c010 is the position: F 03.00, r150, c010 "Foreign currency translation" (Sum of r160 & r170). So, if we see that correctly, the impact of foreign currency translation would be part of {F 03.00, r360,c010} but not part of sum({F 46.00, r200, ({c050}, {c100})}). Consequence is that is not possible that validation rule v1384_m succeeds.

  • 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)
  • ID: 2014_1529
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Large Exposures - maturity buckets

Is it possible to report negative amounts in some maturity buckets of the exposure in LE4 and LE5 templates? According to the validation rules, every column in template LE4 and LE5 should be larger than or equal to zero.

  • 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)
  • ID: 2014_1455
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 13/03/2015

The approach that AMA credit institutions should use when determining the relevant indicator in order to fill in C 16.00 – Operational risk template.

Which is the approach that AMA credit institutions should use when computing the relevant indicator that should be reported in line 130 columns 010-030 of the C 16.00 – Operational risk template?

  • 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)
  • ID: 2014_1448
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Reporting of 10 largest exposures to institutions (correct counting in a case where 2 clients in a group of connected clients are institutions)

How should an institution count "top 10 exposures to institutions" in a case of an exposure to a group of connected clients in which an institution is a parent and there are at least 2 institutions in this group? a) As 1 (of 10) exposure to institutions – because a group of connected clients counts as one exposure when counting top 10 (no matter how many institutions there are in this group) b) As 2 (of 10) exposures to institutions - because there are two institutions in the group of connected clients with a parent institution.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1366
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Table 11.1 - notional amount of derivatives used in two hedge relationshops (fair value and cash flow hedges)

Reporting of notional amount of derivative in more than one hedge relationship: If a derivative (e.g. cross currency swap) is used in two hedging relationships (fair value hedge and cash flow hedge), how should the notional amount of the cross currency swap be reported in Table 11.1? Should the notional of the derivative be reported: a) only once- allocated to one hedge relationship b) reported two times (double reporting)- in both hedge relationship types c) allocated and reported in both hedge relatioship types

  • 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)
  • ID: 2014_944
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Scope of deposit monopoly

According to Article 9(1) of Directive 2013/36/EU (CRD), only credit institutions can carry on the business of taking deposits or other repayable funds from the "public". Will the operation of a group account arrangement within an industrial group - which, inter alia, requires a subsidiary to deposit funds with its parent company - breach the deposit monopoly in Article 9(1) of the CRD? The purpose of such a deposit requirement is generally to optimise the liquidity management within the group. The arrangement only applies to subsidiaries within the group.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1626
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 13/03/2015

Leasing: Residual value risk

In the calculation of the exposure value for residual value risk of leased assets, is the "residual value" that has to be multiplied with 1/t (a) the residual value on the date of calculation / the reporting date or (b) the estimated residual value at the end of the lease term?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1241
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/03/2015

Handling of unrealised gains/losses in Own Funds and Exposures

Does unrealised gains/losses refer to all gains and losses for financial instruments accounted at fair value which occured life to date or only unrealised gains/losses of the current year? Will unrealised gaines and losses despite being deducted from own funds be still part of the exposure? How should the position "Losses for the current financial year" be calculated? Without taking into account unrealised gains/losses?

  • 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)
  • ID: 2014_716
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/03/2015

Reporting "type of connection" in column 040 of LE3 (C 29.00)

What type of connection should an institution report for Client A if "Client A" in a group of connected clients controls "Client B" (cotrol relationship - "a") and is additional economically connected with "Client C" (interconnectedness - "b")?

  • 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)
  • ID: 2013_683
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 27/02/2015

Statement of profit or loss

Can you please clarify what is required by the Annex V guidance on this data point? Two parts of paragraph 24 (the reference given in the template) appear to be inconsistent. The phrase "May be reported" suggests that there is an option about whether or not to classify derivates Held For Trading in this data point, whereas "shall be included" suggests that the income and expense must be shown within interest income and expense, and therefore must be included in this data point 020 or data point 100 for any expense. Further, can you clarify how this paragraph 24 of Annex V relates to paragraph 21? Paragraph 24 is not given as a reference for this data point, but appears to be applicable as it applies to financial instruments Held For Trading. It strongly suggests that it is optional whether to include gains or losses from such instruments within Interest Income/ Expense or Gains and Losses. -------------

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2014_1000
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 27/02/2015

Aggregate Liabilities

Where wholesale funding issuance is undertaken in a currency which is different to the base reporting currency of the institution, and on issuance is swapped back for the duration of the liability (therefore leaving the institution with no currency risk on the transaction), does this issuance count towards the aggregate liabilities cap for single currency reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1579
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/02/2015

Where and how much to report forward starting repo or reverse repo ?

Should article 422.2 and 425.2(d) in CRR be applicable on the initial disbursement flow of forward starting repo or reverse repo for purpose of LCR ? Where to report initial disbursement flows and maturing flows (if within 30 days) of forward starting repo or reverse repo in report C52 and C53?

  • 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)
  • ID: 2014_872
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 20/02/2015

LCR Inflows: current accounts with other credit institutions

Article 425(2)(c) of Regulation (EU) No 575/2013 (CRR) specifies that assets with an undefined contractual end date shall be taken into account with a 20% inflow provided that the contract allows the institution to withdraw and request payment within 30 days. Do current accounts held with other credit institutions fall into that category? If not, how should these current accounts be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1576
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/02/2015

Short positions in financial institution capital instruments

(1) Where a bank holds an item which is treated as a financial institution capital instrument under CRR, can a guarantee or credit default swap over that instrument be considered a short position for the purposes of Articles 45(a), 59(a) or 69(a)? (2) Where a bank has an indirect holding of a financial institution capital instrument, can a guarantee or credit default swap over the host item be considered a short position in the underlying capital instrument for the purposes of Articles 45(a), 59(a) or 69(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1382
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 20/02/2015

Inclusion of interim profits / Deduction of losses in own funds

1. How should the interim profits be calculated for the purposes of inclusion in own funds? E.g. if the bank has monthly P/L as follows: Jan -10, Feb -20, March +100 (Year-to-date +70). The results are not verified by external audit. Should the bank take deduct the losses from Jan and Feb, but ignore the March gain as it is unaudited (capital impact compared to IFRS equity -100) or can the losses be netted with the gains and the YTD gain (unaudited) be filtered out (capital impact -70)? 2. What constitutes 'adequate level of assurance' in context of verification by external auditors? Is a full audit required or is an interim review sufficient?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_384
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 20/02/2015

Exemption of purchased receivables from Aricle 405's retention requirement

Do the provisions in Article 405(1) of Regulation (EU) No 575/2013 apply to purchased receivables?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1474
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 20/02/2015