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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.

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List of Q&A's

Template C 17.00 (OPR DETAILS) – Reporting of loss adjustments

How should a positive or negative loss adjustment be reported in template C 17.00 of Annex I of Regulation (EU) 680/2014 (ITS on Supervisory Reporting)? In particular, how should it be reported in the loss-size buckets (rows 920 – 924 of the 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2016_2867
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

C 04.00 (CA4) form rows 740 to 810 - capital buffer reporting

Do rows 740 to 810 of the CA4 form report monetary values or percentages (buffer rates)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1959
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Reporting of positions in closely correlated currencies (CRR Art. 354)

Template C 22..00 (MARKET RISK: STANDARDISED APPROACHES FOR FOREIGN EXCHANGE RISK (MKR SA FX) wrongly assumes that any pair of currencies closely correlated (row 020) can only be two non-reporting currencies. In fact, one of them can be the reporting currency of the reporting institution. This requires change of the title of the aggregate row 010 as well of the common title of columns 060-080.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_1318
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Risk weighting under standardised approach of an exposure secured by mortgage on residential property being constructed by the borrower (self-build) during the period of construction

Where a residential property is being constructed, and the mortgage loan finances both the construction and subsequent occupation of the property, and also provided that the loan is at all times fully and completely secured by the property in its current condition, for risk weighting purposes it is subject to Article 125 (1) (a) as “residential property which is or shall be occupied or let by the owner”, further assuming it also complies with the conditions in paragraph 2 of the Article, would  the 35% risk weight apply under that Article during the construction period as well as during occupation of the completed property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2304
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 03/02/2017

Capability to perform an impact analysis for 15 consecutive business days for extensions and changes of internal approaches for market risk

Do the regulatory technical standards for assessing the materiality of extensions and changes of internal approaches when calculating own funds requirements (Delegated Regulation (EU) No 529/2014, as amended by Delegated Regulation (EU) 2015/942 for market risk) imply that institutions using internal approaches for market risk shall have the capability to perform a parallel run for 15 consecutive business days for all model changes in their market risk models, such that the materiality of the extension or change can be assessed in accordance with Article 7a(1)(c) of that regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2015/942 - RTS on materiality of extensions and changes in internal approaches for market risk
  • ID: 2016_2763
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/01/2017

Reporting of inflows for term deposits with option for early withdrawal

Which inflow rate should apply to term deposits maturing beyond the 30 day horizon for which the depositor (being the reporting institution) has the option to withdraw its deposit without notice period?

  • 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
  • ID: 2015_2112
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Review and validation of criteria for the use of a reduced number of parameters

For purposes of internal independent review and annual validation of the netting methodology, can the testing be based on historical data from the most recent 100 trading days for the same or similar valuation inputs?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2016_2949
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Exclusion of centrally cleared transactions

How should the terms ‘clearing member’ and ‘client’ be understood for the purposes of Article 382(3) of Regulation (EU) No 575/2013 (CRR)? In Article 382(3) CRR, are clients’ transactions excluded from the perspective of the client only or from both perspectives of the client and the clearing member?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_3009
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Offset of Additional Value Adjustments (“AVA”) against Expected Loss (“EL”) under Article 159

Could the EBA advise whether the reference to “provisions” within the answer to Q&A 2014_933 and 2014_950 refers to specific credit risk adjustments (“SCRAs”)? If so, could the EBA advise if there are any restrictions to the application of AVA against EL as the existing text and level 1 text could be read that any AVA on an IRB exposure would be eligible for offset under Article 159.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1835
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Recognition of unfunded credit protection / guarantees under Advanced IRB

Does an institution which has been granted permission to use the IRB Approach, including to use own estimates of LGD and conversion factors have the option to use the credit risk mitigation techniques of Chapter 4 (general CRM rules) of Regulation (EU) No 575/2013 (CRR), or must it make adjustments using its own estimates?Do the requirements for recognition of CRM under Chapter 4 apply to AIRB firms, or are these superseded by the Chapter 3, Section 6 requirements for IRB firms, including Article 183 CRR regarding recognition of unfunded credit protection for AIRB firms?For the purposes of Art 161(3) CRR, how does one determine the relevant risk weight of "a comparable, direct exposure to the guarantor"? Art 161(4) CRR gives guidance, but this is specifically with regard to the application of Art 153(3) CRR, i.e.: the "double default" approach. Is Art 161(4) CRR also relevant for Art 161(3) CRR?Is the "double default" approach detailed in Art 153(3) CRR and in Chapter 4 (Articles 202 and 217 CRR) also available for AIRB firms?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2593
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Meaning of "credit lines" in the context of conversion factors for certain off-balance sheet items

Which types of off-balance sheet exposures are referred to by the term “other credit lines” in Article 166(8)(d) CRR? Specific clarification is requested (i) for long-term letters of credit arising from the movement of goods, as only such short-term letters are mentioned in Article 166 (8)(b) CRR, and (ii) for guarantees.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2663
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Application level of materiality threshold for assessing the materiality of extensions and changes to the IMA

What is the reference base for the materiality thresholds specified in the technical standards for assessing the materiality of extensions and changes of internal models be applied, if an EU parent institution uses an Internal Models Approach (IMA) on solo and/or (sub)consolidated level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2015_2466
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Calculation of the threshold for using the simplified approach for the determination of AVAs.

Exactly matching, offsetting fair-valued assets and liabilities shall be excluded from the calculation of the threshold for the simplified approach in the determination of AVAs. Does “exactly matching” refer to specific conditions regarding the counterparties of assets and liabilities that otherwise may qualify to be offset?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2016_2756
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 20/01/2017

Risk weighting under the Standardised Approach for credit risk for an exposure secured by a mortgage on a residential property which is a second home (for instance, a holiday home).

Can a second home be a residential property under Article 4(75) of Regulation (EU) No 575/2013 (CRR) and thus a respective mortgage benefit from the 35% risk weight under article 125(1)(a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2641
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Recognition of minorities arising from an intermediate financial holding company

In the example below, are the minority interests of 20% in (mixed) financial holding company no. 1 – after applying the deductions according to Article 84 CRR – eligible for the consolidated own funds of the group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2652
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Exposure secured by immovable property vs. secured by mortgages on immovable property

CRR requires the treatment of exposures secured by mortgages on residential property under the Standardised Approach (Article 124, 125, 126).Also CRR requires the treatment of exposures secured by immovable property collateral (Article 154(3)), and exposures secured by residential / commercial property (Article 164(4)), both under the IRB approach.(Regardless of the residential/commercial distinction), does the different formulation:- “mortgage on immovable property” (Article 124),- “exposure secured by immovable property collateral” (Article 154(3)),- “exposures secured by [residential / commercial] property” Article 164(4))refer to different kind of exposures?Q&A 1214 suggests that the scope is the same for all the three articles above.If however they are not the same, what sort of exposures are part of each group (and not part of another)? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2376
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Risk weight of exposures with QCCPs

Is it possible to use a risk weight according to Article 107(2)(a) of Regulation (EU) No 575/2013 (CRR) for trade exposures with a clearing member, where the institution is a client of a qualifying CCP, which is acting as a general clearing member of a non-qualifying CCP?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 528/2014 - RTS on non-delta risk of options in the standardised market risk approach
  • ID: 2015_2138
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Eligibility of unconditional Financial Letters of Credit as eligible financial collateral

Can an unconditionally drawable Letter of Credit held by an institution as beneficiary be treated as a “cash assimilated instrument” eligible for inclusion by that institution as an item of Funded Credit Protection against an outstanding exposure position for a contingent future payment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_1917
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 06/01/2017

Supplementary transfers when using the sale of business tool

Does the power under Article 38(5) of Directive 2014/59/EU (BRRD) allow the resolution authority to make supplementary transfers even when the conditions for resolution are not met anymore?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2357
  • Topic: Resolution tools and powers
  • Date of submission:
  • Published as final Q&A: 16/12/2016

Classification of SME/Retail Corporates as 'Retail Deposits'

To be eligible for Article 153(4) CRR, do firms need to have externally verified annual sales numbers, and if so how frequently should firms assess eligibility?

  • 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
  • ID: 2016_2731
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 09/12/2016