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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

Transfer to a recipient in full under a partial transfer

Is it possible to transfer certain classes of eligible liabilities to a recipient in full even in case not all liabilities of an institution are transferred to that same recipient?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2436
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Reimbursement of shareholders and creditors

In our understanding, Articles 36(12) and 46(3) confer upon the resolution authority a mere power - not an obligation - to reimburse shareholders and creditors. If this is the case, is such power an unfettered discretion or should it be exercised under particular conditions? If the latter is correct, which conditions apply?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2351
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Final valuation lower than the initial valuation

What are the consequences of final valuation being lower than the initial one?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2187
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Same valuer for provisional and final valuation

Can the resolution authority outsource the provisional valuation? If yes can the same valuer prepare provisional and final valuation?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2186
  • Topic: Valuation
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Consistency between Early intervention measures in BRRD and CRD IV

How can consistency between the Early intervention measures as listed in Article 27 of Directive 2014/59/EU (BRRD) and those already envisaged in Article 104 of Directive 2013/36/EU (CRD IV) be ensured, in particular taking into account that the triggers for these measures are partially different?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2107
  • Topic: Interactions with the CRR / CRD IV and the BRRD
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Operational Deposits Arising From The Provision of Operational Services (Clearing, Custody and Cash Management)

How should firms assess/identify the presence of 'operational limitations that make significant withdrawals within 30 calendar days unlikely' and the level of funds that are 'required for the provision of operational services'?

  • 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_2647
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 28/10/2016

‘Indirect holdings’ in capital instruments issued by financial sector entities (CRR Article 4 paragraph 1 subparagraph 114).

The definition of indirect holdings requires that the institution performs an internal assessment in order to determine if, in the event the capital instruments issued by the financial sector entity were permanently written off, the loss that the institution would incur as a result would not be materially different from the loss the institution would incur from a direct holding of those capital instruments. Can the institution use stress scenarios that are already utilised by the institution for internal risk management purposes when making this assessment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2783
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Market Risk Netting Under Article 331 (2)

Does Article 331(2) apply to both notional positions produced from a futures contract as per Articles 328 or just to the positions created in the underlying instrument, or just to the position created in a notional instrument that matures on the delivery date of the futures contract? For example a bond future produces both a notional position in a deliverable bond and a notional position for the cash movement at the future expiry.a) Does Article 331(2) apply to both of these notional positions, or just to the notional position created in the deliverable bond, or just to the notional position created for the cash movement at the future expiry?b) Please confirm if the notional position created in the deliverable bond should be included in a net bond position calculation under Article 327(1), and excluded from netting under Article 331(2), while the notional position created for the cash movement should be excluded from Article 327(1) and included in Article 331(2) netting with only other cash movement notional positions.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2533
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 28/10/2016

Appropriate risk weight for speculative immovable property financing

Does CRR Article 128 (1) provide that a 150% risk weight need not be applied to one or more exposures listed in CRR Article 128 (2) - including speculative immovable property financing - or that are identified in accordance with CRR Article 128 (3), on the basis that it would not be appropriate to apply that rate to such an exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2268
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/10/2016

Treatment of cases spanning more than one year in Own Funds templates (Annex I - Reporting on own funds and own funds requirements) - Six month tables

COREP template C 17.00 – OPERATIONAL RISK: GROSS LOSSES BY BUSINESS LINES AND EVENT TYPES IN THE LAST YEAR (OPR Details) summarises the information on the gross losses registered by an institution in the last year according to event types and business lines, based on the first accounting date of the loss.What we would like to clarify, is the treatment of incidents that span more than one year, and consequently get recorded in the books of the institution in parts for several years. The question is whether the amount included in this table should be the incremental amount (i.e. the amount that was recorded for an incident only in the last 12 months from the report date, and which could mean positive amounts, due to possible reversals of previous provisions) or if it should be the sum of the amounts (i.e. cumulative amount) recorded for that incident over all the years, including the latest amount which was recorded in the last 12 months.Please find here three examples illustrating the above question, for which we would like a clarification:An operational loss event (e.g. a lawsuit against the bank where the probability of a negative outcome is >50%) that was recorded (date of input) in 2009 with an initial estimated loss amount (Potential Loss) of € 300 (28/01/2009).30/11/2011The estimated loss amount has been increased by € 200 to € 500Question: 30/11/2011 and next 12 months, should they report € 200 or € 500?At final Settlement (30/06/2014):Case 1:Case closed – final settlement – The bank paid € 400 (favourable)Question: 30/06/2014 and next 12 months, should they report - € 100 (negative) or € 400?Case 2:Case closed – final settlement – The bank paid € 600 (unfavourable)Question: 30/06/2014 and next 12 months, should they report € 100 or € 600?A fraud incident that was recorded (date on input) in 2010 with an initial loss of € 80 (25/05/2010).02/02/2011 – the loss has been increased by € 50 to € 130.Question: 02/02/2011 and next 12 months, should they report € 50 or € 130?Incidents that are recorded (date of input) with an initial loss amount lower than € 1000 (Lowest threshold) but their loss amount is rising above € 1000 in the subsequent years.Question: How should this be treated? Should the full amount of the loss appear on the first time the incident 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_1694
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Group Solvency report: The content of the column 390 “Contributions to consolidated result” of the Group Solvency report

Does the content of column 390 “Contributions to consolidated result” of the Group Solvency report correspond with the row 130 “Retained earnings” of the CA1 report (C 01.00) on group level (subgroup level) or rather with the sum of the rows 280 “Cumulative gains and losses due to changes in own credit risk on fair valued liabilities” and 285 “Fair value gains and losses arising from the institution's own credit risk related to derivative liabilities” of the CA1 report on group level (subgroup level)?Expressed as formulas: {GS;c390} = {CA1;r130} or {GS;c390} = {CA1;r130} + {CA1;r280} + {CA1;r285}? (Regulation (EU) No 680/2014 [ITS on Reporting], Annex II, C 06.00, c390)

  • 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_1398
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Group Solvency report: Reporting of the columns 300 to 350 and columns 360 to 400

Shall a consolidated entity which contributes to the group’s consolidated own funds by minority interests but also by other means exclusively report columns 300 to 350 or additionally columns 360 to 400? (Regulation (EU) No 680/2014 (ITS on Reporting), Annex II, C 06.01 / C 06.02, c300 to c400)

  • 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_1396
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

F 07.00: Validation Rules v0817_m, v0818_m, v0822_m, v0823_m, v0824_m

We assume that validation Rules v0817_m, v0818_m need to be corrected for F 07.00, column 110 and v0822_m, v0823_m, v0824_m for F 07.00, columns 080 and 090, because the sign >= does not work in this case for negative numbers. Can you please confirm?

  • 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_1331
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Template F 22.01: Fee and commission income and expenses by activity

Should a bank report all commission income / expenses in template F 22.01 or just the part related to off balance sheet activities?

  • 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_1219
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Is validation rule v3897_s correct and shall be strictly adhered to?

There are a number of sign validation rules which are applied to the FINREP templates. Are all of them correct and shall be strictly adhered to?For example, rule v3897_s requires that all items in template F 01.01 (FINREP) are greater or equal to 0. This validation may not be applicable for some of the items in template F 01.01, such as row 250 – 'Fair Value changes of the hedged items in portfolio hedge of interest rate risk'. As this item (row 250) may be a contra-asset account (i.e. reducing the total assets balance), shall it nevertheless be reported as a positive number (as required by 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_1204
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Template C 09.02 (CR GB2) – Row 040 Specialised lending under the slotting criteria

Should 'Corporate Specialised Lending' reported within row 040 exclude specialised lending under the slotting criteria?

  • 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_1185
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

CA3 - rows 110 and 120

CA3 row 110 and 120 only need to be populated if a competent authority decides that a bank has to meet a higher target total capital ratio (r120) or has an impact on the total capital ratio (r110). Can you please advise, whether these cells need populating or not.

  • 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_1136
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

F 09.02 & F 13.01: Maximum amount of the guarantee that can be considered

Please we would like to know what the differences are between the reporting of the "maximum amount of guarantee that can be considered" in templates F 09.02 and F 13.01. Why are these concepts not equal?In question ID 2013_338 it is stated:(...) since for F 09.02, the amount is the maximum amount the counterparty could have to pay if the guarantee is called on, and in table F 13.01, the amount of guarantee shall not exceed the carrying amount of the related loan.

  • 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_1129
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Validation Rule v0629_m

Can rule v0629_m be valid in any case? Namely, in some cases (see background information) the own funds requirements for foreign exchange stipulate that the foreign exchange risk be calculated as the sum of its overall net foreign exchange position and its net gold position in the reporting currency, multiplied by 8 %, not by 12,5%, which is what the rules, in effect, validates.

  • 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_1107
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016

Validation Rule v2245_h

Should column 090 from form CR GB 2 still be in the scope of validation rule v2245_h? As the rule validates a sum and column 090 contains percentages it cannot be 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: 2014_1101
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 14/10/2016