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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

Transfer of covered deposits as a substitute to reimbursement

Can resolution authorities take resolution action, e.g. a transfer of the deposit book, restoring access to covered deposits, even after such access has been interrupted and the conditions laid down in Article 2(1)(8) of Directive 2014/49/EU (DGSD) are met?In such a case, what is the effect of such action on the obligation of the DGS under Article 8(1) DGSD (repayment obligation) and 109(1) of Directive 2014/59/EU (BRRD) (contribution in resolution)?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2123
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 05/08/2016

Calculation of MREL

For the purpose of calculating the total liabilities, including own funds of the resolution entity, as provided under Article 45b(4), (5) and (7) BRRD, should we account for financial instruments that qualify as both own funds and liabilities (such as subordinated debt) in both categories? If so, would this not amount to a double counting of the same financial instruments?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2120
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 05/08/2016

Definition of client funds

Is it sufficient to refer to "client assets" in the list of resolution objectives, if the definition of "client assets" at a national level includes "client money"?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2111
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 05/08/2016

Reporting of Regulatory High Risk Items in default in C 09.01

Please can you advise how Regulatory High Risk exposures which are in default should be reported in C 09.01?

  • 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_1646
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Should National GAAP reporters fill in template F 18.00 and F 19.00 on non-preforming and forborne exposures?

Should National GAAP reporters fill in template F 18.00 and F 19.00 on non-preforming and forborne exposures?

  • 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_2415
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

The 3 largest material currencies in the structural currency mismatches tables (P 02.06) of funding plan report

According to the instructions for P 02.06, the table provides a breakdown of the 3 largest material currencies. The currency is material if it accounts for more than 5% of total liabilities, as per Art 415 (2) lit. b CRR. (We think the correct reference here is Art 415 (2) lit. a CRR.)According to Art. 415 (2) lit. a) CRR,: an institution shall report separately to the competent authorities of the home Member State the items referred to in paragraph 1 in the currency below when it has:(a) aggregate liabilities in a currency different from the reporting currency under paragraph 1 amounting to or exceeding 5 % of the institution's or the single liquidity subgroup's total liabilitiesDoes that mean that the reporting currency has to be reported?If yes, how shall the reporting currency – take the Hungarian forint as example - be reported in the structural currency mismatches tables of funding plan report?

  • 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_2329
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Clarification on Funding Plans significant currencies criteria

What rule should be followed given the discrepancy between what the EBA Guideline establishes and the criteria given by the template GL on FP?

  • 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_2388
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Design of Templates for 3-year horizon

The guideline provides Templates for 3-year horizon with 5 columns:Actual Current Position (e.g. end 2013)Planned 6 month Position (e.g. H1 2014)Planned Year 1 Position (e.g. end 2014)Planned Year 2 Position (e.g. end 2015)Planned Year 3 Position (e.g. end 2016)For the year 2015 institutions report their funding plans with the reference date (Actual Current Position) 30 June 2015.For subsequent years institutions report their funding plans with the reference date 31 December of previous year. Our understanding is that for the year 2016 FP templates should be designed as follows:Actual Current Position (end 2015)Planned Year 1 Position (end 2016)Planned Year 2 Position(end 2017)Planned Year 3 Position (end 2018)We are not sure if our understanding of FP templates for the 2016 and further (without Planned 6 month Position (H1 2016) is correct?

  • 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_2127
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Funding plans projection horizon for the June 2015 reference date

Can you please clarify whether the projection horizon for the June 2015 reference date relates to (a) Dec 2015, June 2016, June 2017 and June 2018 for each of columns 020 to 050 respectively, or (b)Dec 2015, Dec 2015, Dec 2016 and Dec 2017 for each of columns 020 to 050 respectively

  • 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_2048
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Funding Plans : Table 2C (P 02.06) - Gradation of currencies in the taxonomy

In Table 2C (P 02.06), there is a notion of gradation on currencies' breakdown (1st, 2nd, and 3rd Largest material currency). But for now, the taxonomy don't handle this gradation. Does that mean that we can report the three most significant currencies regardless of their rank of importance?

  • 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: 2014_1521
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Loans collateralized by immovable property in F 05.00 and F 13.01

Do loans collateralized by immovable property in template F 05.00 contain only residential and commercial immovable property, like in F 13.01, or are they open to other collateralized immovable property (those which do not meet the definition of residential and commercial provided by CRR)? If the former, are those loans collateralized by other immovable property reported as other loans collateralized?

  • 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_1108
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

GL on funding plans: treatment of loans/deposits on demand across different items in Table 1a - Assets (P 01.01)

How should "Other demand deposit (with credit institutions)" be treated across different items of the Table 1A - Assets (P 01.01) in funding plans in order to avoid double counting? Furthermore, is it relevant to exclude loans on demand from the household sector?

  • 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_1936
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Entry criteria NPE for forborne exposures under probation

Entry criteria for NPE according to paragraph 179 are stricter than exit criteria according to paragraph 156. This can lead to an infinite circle of reclassifications.

  • 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_1014
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/07/2016

Conditions for Resolution

At what point of time during a resolution procedure must the conditions for resolution pursuant to Article 32(1) BRRD be met? Is it necessary to only positively assess them at the initiation of the resolution process, i.e. at the moment the resolution authority initiates a resolution procedure?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2428
  • Topic: Resolution objectives and triggers
  • Date of submission:
  • Published as final Q&A: 22/07/2016

Risk weight for exposures to central-government-risk Public Sector Entities (PSEs) denominated and funded in domestic currency

May exposures to PSEs established in a Member State, whose level of risk in the opinion of the competent authority of the Member State in question does not differ from the level of risk of the central government, be assigned a risk weight of 0% in accordance with Article 114(4) of CRR if they are denominated and funded in domestic currency?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2484
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/07/2016

Definition of "institution" for large exposure purposes

Should EC implementing decision on the equivalence of the supervisory and regulatory requirements of certain third countries and territories for the purposes of the treatment of exposures according to Regulation (EC) No. 575/2013 be used to determine equivalence for LE purposes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1692
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 15/07/2016

Investment in Tier 2 capital by subsidiary

Article 63(b)(ii) of Regulation (EU) No 575/2013 (CRR) states that capital instruments and subordinated loans shall qualify as Tier 2 instruments provided that particular conditions are met. One of such condition requires that the instruments are not purchased or the subordinated loans are not granted, as applicable, by either the institution or its subsidiaries.Is it a correct approach that only the part of capital instruments which is not currently held by subsidiary should be qualified as Tier 2 instruments?Should an institution apply for permission for the whole issue and after that exclude instruments held by subsidiaries, if national law requires a special permission from the competent authority in order to recognize instrument as Tier 2 capital? And after being granted this permission should the institution exclude in day-to-day adequacy calculation the amount of instruments held by subsidiary?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2392
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/07/2016

Depositor preference where the deposit is recived from a fiduciary

Do deposits received from financial institutions on behalf of clients that are individuals and SMES benefit from depositor preference.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2015_2452
  • Topic: Interactions with the DGS and the BRRD
  • Date of submission:
  • Published as final Q&A: 01/07/2016

Promotional banks

Is there a list of all EU institutions qualifying for the notion of "promotional bank"?

  • 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_2223
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 01/07/2016

Template 105.01 filling for LDPs

Should the template 105.01 be filled also for LDPs?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2015_2503
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/06/2016