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List of Q&A's

Calculation of 17.65% CET1 threshold

In CRR article 48(2) it 19s defined calculation of threshold as follows:"2. For the purposes of paragraph 1, the threshold amount shall be equal to the amount referred to in point (a) of this paragraph multiplied by the percentage referred to in point (b) of this paragraph: (a) the residual amount of Common Equity Tier 1 items after applying the adjustments and deductions in Articles 32 to 36 in full and without applying the threshold exemptions specified in this Article;(b) 17,65 %."However in the instruction of the ITS on supervisory reporting on row 210 of CA4 is supported by Article 48(1) of CRR and explains the following:"This item contains the 17.65% threshold for holdings in financial sector entities where an institution has a significant investment, and for deferred tax assets that are dependent on future profitability and arise from temporary differences, to be applied after the 10% threshold.The threshold is calculated so that the amount of the two items that is recognised must not exceed 15% of the Common Equity Tier 1 capital, calculated after all deductions, not including any adjustment due to transitional provisions."As the respective article 48 points (1) or (2) do not refer to 15% threshold, this reference in annex 2, in row 210 of CA4, in last paragraph to, 1815% of the Common Equity Tier 1 19 should be read as '17,65% of the Common Equity Tier 1'?Or does the threshold 17,65% of row 210 of CA4 actually includes calculation of 15% threshold? In this case, how? 

  • 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_1180
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Validation rule v4421_s does not comply with validation rules v4117_m, v4118_m, v4119_m, v4120_m as it implies a negative sign for maturing long term funding

Validation rule v4421_s implies that maturing long term funding must be reported with a negative sign for different categories of long term funding in row (200,230, 260,290,320) and column (020,030,040,050) in template P 01.02. However, this contradicts with validation rules v4117_m, v4118_m, v4119_m and v4120_m.

  • 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_2046
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Funding plan for credit institutions: meaning of "maturing gros outflow"

regarding to table P01.02 row 200, the definitional reference states "Instruments of this type which are contractually due to mature during the time from the end of the previous period to the relevant period-end".

  • 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_1969
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Difference between and Annex I/ Annex II/1.6 description and DPM descrption of the same table name

There is a difference regarding the name of table C 05.02 Capital Adequacy, between Annex I sheet C 05.02/ Annex II Own funds paragraph 1.6 and DPM Database/ DPM Table Layout. While in Annex I/II name is 'Grandfathered instruments: Instruments NOT constituting State aid (CA5.2)' in DPM Database/DPM table layout, namie is 'C 05.02 - Capital Adequacy - Transitional provisions: Grandfathered instruments constituting State aid'. Please confirm what name is correct and should be used for table C 05.02 Capital Adequacy related to Grandfathered instruments (with NOT or without '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_1305
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Incorrect legal references

Which are the correct legal references of the item in row 020 of template Grandfathered Instruments: Instruments not Constituing State Aid (C05.02)?

  • 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_1269
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Operational Risk templates

In order to fulfill the information of operational risk losses, we would like to know if we should include the following concept of losses: -Operational risk related credit risk losses. Losses included in the credit risk capital data base, but originated for an operational risk event.

  • 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_1233
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Group Solvency template (C06.00) – information on the contribution of entities to solvency of the group (columns 300 to 400)

On what basis should the contribution of entities to solvency of the group (columns 300 to 400) 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: 2014_1193
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Incorrect references to the CRR

In Annex 1, C 05.02 'Grandfathered instruments: Instruments not constituting State Aid' there are some wrong references to the CRR articles, as follows: - row 020 and row 090 - instead of 'Article 489', it should be 'Article 486'; - row 050, row 060 and row 070 - instead of 'Article 49 of CRR', it should be 'Article 52 of CRR'. Limits for grandfathering of items within CET1, AT1 and T2 are in Article 486 of the CRR. Conditions for AT1 quialification are in Article 52 of the CRR.

  • 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_1191
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Template C07.00 Column 230: of which: with a credit assessment by a nominated ECAI

Column 230: of which: with a credit assessment by a nominated ECAI, is this column only reported for exposures where the ECAI rating was used to determine 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: 2014_1188
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Fiduciary loans and deposits

Considering that for FINREP reporting the fiduciary loans and deposits are explicitly excluded from Balance Sheet could you please advice whether the same treatment applies to COREP (including Large Exposures) reporting? That is, if fiduciary loans and deposits should be excluded from all COREP and Large Exposure reports.

  • 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_1088
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Non Performing Loans at group levels.

Clarification is requested as to when group (connected) accounts should be downgraded to the Non Performing category (NPL) when only one party from within this group classifies as an NPL (refer to the 2nd part of para. 155). Should group facilities be downgraded: 1. When exposures past-due by more than 90 days represent 20% of the gross carrying amount of a singly debtor (one party within group entities) or 2. When exposures past-due by more than 90 days represent 20% of the gross carnying amount of the total group exposure? or is this left at the discretion of the credit institution? 

  • 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_1113
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Maturities in Large exposure report (LE4; top 10)

How should we interpret and apply the reference to the instructions of the maturity ladder template of the additional metrics on liquidity in Annex IX 18Instructions for reporting large exposures and concentration risk 19?

  • 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_1137
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Template C07.00 Column 240: of which: with a credit assessment derived from Central Government

Column 240: of which: with a credit assessment derived from Central Government, is this column only applicable to exposure classes institutions, public sector entities or regional governments and local authorities? Or should it also include corporates under CRR Article 122.2 where the risk weight was derived from the central government of the jurisdiction in which the corporate is incorporated?

  • 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_1187
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Splitting exposures

In the case that an exposure has attributes that it can be assigned into various exposure classes, may it be divided into two exposure classes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2560
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/09/2016

Outflows from operational deposits

What is the difference between deposits arising from clearing accounts of financial institutions and deposits arising from correspondent banking?

  • 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_2784
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 26/08/2016

Temporary discontinuance of access to deposits in resolution

Where resolution action is taken in relation to an institution, e.g. open bail-in or transfer of the deposit book to a sound acquirer, which ensures an immediate prospect of quickly ensuring access to deposits, to what extent can access to covered and eligible deposits be temporarily discontinued without triggering the Deposit Guarantee Scheme (DGS) repayment or rendering the resolution action illegal?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2122
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 26/08/2016

Interaction of the EBA Opinion on the MDA and Article 92 Regulation (EU) No 575/2013 (CRR)

Where a bank does not have sufficient subordinated debt in issue to fulfil its minimum 1.5% Tier 1 and 2.0% Tier 2 requirement, it may need to use a higher quality form of capital to fulfil these requirements.To the extent a bank has to assign CET1 to fulfil shortfalls in its minimum Tier 1 and Tier 2 requirements, can this CET1 also be applied to meet Pillar 2 and Combined Buffer requirements for the purpose of calculating the MDA? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2016_2552
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 26/08/2016

SREP and combined buffers

Article 104(1)(a) of the Directive 2013/36/EU (CRD) states that competent authorities have the power to require institutions to hold own funds in excess of the requirements set out in "Chapter 4 and Regulation 575/2013", i.e. in excess of the minimum capital requirements set in the CRR plus the capital buffers. Moreover, Articles 129(5), 130(5) and 131(13) of the CRD prevent the use of CET1 capital required per Article 104 to meet any of the buffer CET1 requirements.1) When the competent authorities give to an institution an individualised CET1 capital requirement (so-called SREP requirements or Pillar 1 + Pillar 2 requirements), does this include any potential combined buffer requirements, since any additional requirement per Article 104 should come on top of the requirements imposed by Chapter 4 of the CRD and by the CRR ?2) In particular, if a competent authority changes the systemic risk buffer (SRB) or the other systemically important institutions buffer (O-SIIB) applicable to a bank would this not increase the total Pillar 2 + Pillar 1 requirement of the bank, unless the new Pillar 1 requirement went above the old Pillar 1 + Pillar 2 requirement or unless the competent authority also changed the total SREP requirement of the bank?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2302
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as final Q&A: 26/08/2016

Is collateral from REPO and SBL transactions taken into consideration for the BRRD base calculation?

Could liabilities arising from repos and securities lending and borrowing transactions be netted with the collateral posted what would result in a BRRD base decrease?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2016_2765
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 12/08/2016

Application of the even deduction rule in case of intragroup transactions booked - by institutions which are parties to the contract - in different amounts

How to apply the even deduction rule stipulated in the Article 5(2) of the Commission Delegated Regulation (EU) 2015/63 and further clarified by the EBA Q&A 2015_1893 (Treatment of specific liabilities - even deduction) in cases where each party books the transaction in different amount?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2015_2283
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 05/08/2016