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List of Q&A's

Rules on qualifying holdings in credit institutions

a) Do the rules on notification and assessment of proposed acquisitions of qualifying holdings apply to legal mergers between credit institutions? Is this assessment dependent on whether the merging entities belong to the same group or not?b) Can a competent authority oppose a proposed acquisition, on the basis of concerns related to financial stability. More specifically, can a competent authority oppose a proposed acquisition due to lack of agreement on Memorandums of Understanding on branch supervision between the home state of the acquiring entity and the home state of the acquired entity (which will be host state following the acquisition and future integration)?c) Can a competent authority refuse to make a decision on a proposed acquisition of a qualifying holding and thus exceed the maximum assessment period of 60 working days due to lack of agreement on Memorandums of Understanding on branch supervision between the home state of the acquiring entity and the home state of the acquired entity (which will be host state following the acquisition and future integration)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3010
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 03/02/2017

COREP C 17.00 - operational risk / losses to be reported

In COREP C 17.00, is there a definition of which losses have to be reported related to usury and compound interest? Our bank also includes losses here that are linked to credit risk (to be more specific: fraud linked to credit risk). Although fraud is indeed covered by COREP C 17.00, we understand the underlying rules of COREP C 17.00 to be "operational losses only". However, we are unsure what the correct interpretation of "operational losses" is here. For the determination of capital requirements, should these credit-risk related fraud losses be captured within the operational risk (so COREP C 17.00) or within the credit risk?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2016_2874
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Original Exposure Pre-Conversion factors

Should column 010 of CR SA (C 07.00), "Original Exposures Pre Conversion factors" be reported based on Secured/Unsecured part of the exposure?

  • 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_1636
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

C 41.00 - Inconsistency between Validations and EBA member/dimension types causes validation v0668_m to fail

Validation rule v0668_m states that r{r010} = sum(r020-100). We believe this validation rule will fail due to the fact that the categorisation of row 100 (x3 - 'Defaulted') for dimension Impairment status is different than the one for row 010 (x5 -'Non defaulted') which represents the total as per the validation rule.

  • 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_1466
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting of deductions of receivables assets for cash variation margin provided in derivatives transactions in LR4 (C43.00)

In which row(s) shall the receivables for cash variation margin provided in derivatives transactions be reported?

  • 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: 2016_2982
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting template C40.00 (LR1): Validation rules v0101_h and v0102_h should be amended

Should column 070 of C40.00 be exempted from the application of validation rule v0101_h and v0102_h?

  • 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: 2016_2981
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting LR2 - exposures to consider?

In Template CRD41 / LR2, shall we include or exclude derivatives and SFT's in the exposures distributed by risk weighted? The regulation is focusing on ON and OFF balance sheet items while the title of the Template mention "Total on- and off-balance sheet exposures belonging to the banking book as well as exposures of the trading book subject to counterparty credit risk (breakdown in accordance with the risk weight):".

  • 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: 2016_2945
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Inconsistency between a template and instructions regarding F 09.01

Point 61 in Part 2, Annex V of Commission Implementing Regulation (EU) No 680/2014 specifies what is included in rows "of which: defaulted" in the FINREP template 9.1 (F 09.01). However, if we look at that template, it contains rows named "of which: non-performing". Which is correct?

  • 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: 2016_2928
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Allocating Revaluation Reserves in F 46.00 / Difference Total Comprehensive Income in F 46.00 and F 03.00

The Total comprehensive income for the year in table F 46.00 should be equal to the Total comprehensive income for the year in table F 03.00. All tables in the FINREP should comply with IAS/IFRS. There are two validation rules to ensure this reconciliation: V1383_m (Blocking) and V1384_m (Non-Blocking) Validation rule V1384_m takes into account less items for the Total comprehensive income in F 46.00 than does validation rule V1383_m. V1384_m does not take into account Item Revaluation reserves in F 46.00, which is taken into account for the Total comprehensive income in F 03.00. How can one comply with both V1383_m and V1384_m at the same time, when both validation rules take into account different line-items?

  • 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: 2016_2911
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

FINREP Taxonomy 2.5 Templates 04.04/18.00.b Validations

In taxonomy 2.5, are validations v3049_m to v3076_m the correct way round? That is, should the “<=” sign be “>=”?

  • 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: 2016_2899
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Clarification of the collateral amounts

Could you please clarify the amounts which need to be reported in column 150-210 of template C08.01 for funded credit protection and where the institution uses its own LGD estimates? Is this the value which is used in the LGD estimation (taking into account article 181 (1) (e) and (f)) or is it solely the estimated market value (without any haircuts)?

  • 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: 2016_2866
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

FINREP validation rules

Validation rules v1702_m and v1703_m seem to be uncorrect

  • 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: 2016_2850
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Invalid CRR article reference within leverage ratio ITS (regulation (EU) 2016/428)

The instructions for cells {180;020} and {180;040} of the leverage ratio report 'C43.00 — Alternative breakdown of leverage ratio exposure measure components (LR4)' contained in the leverage ratio ITS make reference to "exposures in the form of covered bonds under Article 161(d) of the CRR". "Article 161(d)" is not a valid reference to the CRR. Is the intended reference 'article 161(1)(d)'?

  • 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: 2016_2843
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Realisation of collateral and unlikeness to pay

Is exposure considered non-performing according to Art 145(b) ITS also in the case where: (i) the debtor is assessed as unlikely to pay its credit obligation without collateral either being repossessed or sold voluntarily; (ii) a voluntary sale is assessed as highly feasible.

  • 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: 2016_2842
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Validation rule v4134_m

According to us the validation rule v4134_m is currently not correct or complete. It compares the rows 010 and 020 (DGS covered and uncovered) from table P02.01 with rows 020, 060 and 120 from table P01.02. It however, does not include the amounts in row 180 in table P01.02 (debt securities issued) although those can also be covered by a DGS (at least in Belgium).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2016_2714
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Validation rule v4574_m

Is validation rule v4574_m correct?

  • 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: 2016_2630
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting transitional adjustments to RWA in C 05.01

We observe different treatments in practice on how transitional adjustments to RWA are reported in template C 05.01. From the reporting instructions we find two interpretations possible: that the whole amount of RWAs is reported or that only the adjustment compared to a fully loaded approach, per se, is reported.

  • 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_1657
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Validation Rule v3812_s

This validation rule indicates that column 010 of C43.00a should be positive or equal to zero. For row 060; this amount could be negative in case of portfolio of repos that fulfill conditions of Article 429 - 11.

  • 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_2444
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Deposits reported in P 01.02 and in P 02.01

This question aims to clarify the validation rule v4134_m of the Funding Plan template. This validation rule states that the total deposits reported under "P 02.01 - Insured and uninsured deposits" must be equal or smaller than the deposits reported on lines 020, 060 and 120 of the frame "P 01.02 - Liabilities". Due to several reporting issues we intend to clarify if the total deposits reported under "P 02.01 - Insured and uninsured deposits" only refer to retail deposits under the Article 411.2 of CRR

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2015_2425
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Differentiation between specialised lending and sme exposures within exposure class corporates

The exposure class 'corporates' is splitted into sme, specialised lending and other corporates. Where must an institution report specialised lending exposures, that are at the same time exposures to sme? The implemented sme definition only the annualised returns (< 50 mln. EUR). Specialised lending exposures are identified through the rating methodologies, that have been applied to determine a credit quality.

  • 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_2259
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017