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Exit criteria for performing exposure under probation that has been reclassifiied to non-performing because it has been re-forborne or is more than 30 days past-due

According to paragraph 180 non-performing exposures with forbearance measures comprise forborne exposures that meet the criteria to be considered as non-performing. These exposures are forborne exposures which have been reclassified from the performing category, including exposures under probation having been re-forborne or more than 30 days past-due. However, which exit criteria does apply to cease being non-performing for this specific non-performing exposure?

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_886 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 27/02/2014 | Date of publication: 03/10/2014

Forbearance - Arrangement to Pay and Promise to Pay

The question concerns the identification of forbearance measures, namely the ‘Arrangement to Pay’ and the ‘Promise to Pay’. With this question I want to propose that an Arrangement to Pay will not be classified as forbearance. I would like to know whether you agree on my conclusion. Forbearance (EBA definition) Debts with forbearance measures are contracts / the terms (1) of which the debtor is considered unable to comply with (2) due to its financial difficulties so that the institution decides (3) either to modify the terms and conditions of the contract to enable the debtor to service the debt or to refinance, totally or partially, the contract. When determining whether a measure constitutes as forbearance the following aspects should be taken into account: A. Is the counterparty in financial difficulties? B. Is there a modification of the terms and conditions of the contract? C. Is the modification a concession? D. Is the classification of forbearance aligned with the objectives of the regulator?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

ID: 2013_654 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 13/12/2013 | Date of publication: 03/10/2014

v0679_m: taxonomy is incorrect.

The validation rule for the RWA of the off-balance sheet items (C43.00 r010, c020) only considers the RWA of the off-balance sheet items subject to credit risk in Total-Standard approach (C 07.00a r080, c220, s001) and the RWA of the off-balance sheet items subject to credit risk in Total-IRB Approach to capital requirement with own estimates of LGD and/or conversion factors (C 08.01a r030, c260, s001). Should the RWA of the off-balance sheet items subject to credit risk in Total-IRB Approach to capital requirement without own estimates of LGD and/or conversion factors (C 08.01a r030, c260, s002) also be considered in this 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 (as amended)

ID: 2014_1251 | Topic: Supervisory reporting - Leverage ratio | Date of submission: 28/05/2014 | Date of publication: 03/10/2014

What day count convention is to be used in Regulation (EU) No 575/2013 (CRR) Art.116 (3)

What day count convention is to be used in Regulation (EU) No 575/2013 (CRR) Article 116 (3) ?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2014_1103 | Topic: Credit risk | Date of submission: 24/04/2014 | Date of publication: 03/10/2014

Treatment of Croatian currency - Kuna (HRK) and Croatian national market in Market risk reporting templates

We have noticed that there is no code for Croatian currency (HRK) as pre-defined separate reporting currency in templates C18 and C22 and no code for Croatian market as pre-defined separate reporting market in template C21.

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 (as amended)

ID: 2014_1370 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 16/07/2014 | Date of publication: 26/09/2014

Lines 290 to 320 of the CR SA’ state

1/ For lines 290 and 310, are the columns "215" and "220" matching the exposures’ weighted amounts if they were not secured by a mortgage or is it necessary to declare the same weighted amounts shown in line 010 classified according to the category of the exposure’s original counterpart. 2/ For lines 300 and 320, is the column "215" matching the exposures’ weighted amounts if they were not in default or is it necessary to declare the same weighted amounts shown in line 010 classified according to the category of the exposure’s original counterpart. 3/ Lines 300 and 320 of the CR SA’ state concern defaulted exposures for which categories before being in default were as such: - Central governments and central banks - Regional and local administrations - Public Sector Entities - Institutions that are not subjected to an evaluation of short-term credit - Businesses/Corporates that are not the subjected to an evaluation of short-term credit - Retail (customers ) Can you confirm that defaulted exposures secured by a mortgage are not affected by lines 300 and 320 of the CR SA state? However, they will be reported in the column "020" of the line 90 of the CR GB 1 state.

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 (as amended)

ID: 2014_1163 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 07/05/2014 | Date of publication: 26/09/2014

Different ID

Why "Public sector entities" dimension in the table C 07.00 does not have same type of linking to the table C 02.00 as does have for example "Regional governments or local authorities" dimension?

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 (as amended)

ID: 2014_1090 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 22/04/2014 | Date of publication: 26/09/2014

Validation rule v3995_u

Please check the appropriateness of validation rule (v3995_u) "{C 27.00, c010} is a row identifier, and must be unique for each row in the table"

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 (as amended)

ID: 2014_1080 | Topic: Supervisory reporting - Large Exposures | Date of submission: 17/04/2014 | Date of publication: 26/09/2014

Risk weighted exposures of CET1 holdings in financial sector entities which are not deducted from the institution's CET1 capital

ITS instructions for Annex I, C04.00, r650, c010 refer to article 46.4 that only deals with non significant investments in financial sector entities. Heading of reporting line seem to indicate that all the holdings (be significant or not) in financial sector entities should be reported there if not deducted from own funds. Can you clarify?

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 (as amended)

ID: 2014_1037 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 01/04/2014 | Date of publication: 26/09/2014

Header in Template C_09.02 has incorrect wording

The header for column 125 in Template C.09.02 reads: RISK WEIGHTED EXPOSURE AMOUNT PRE AFTER SME-SUPPORTING FACTOR The correct heading is: RISK WEIGHTED EXPOSURE AMOUNT AFTER SME-SUPPORTING FACTOR

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 (as amended)

ID: 2014_1024 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 27/03/2014 | Date of publication: 26/09/2014

Geographical Breakdown

We have found differences between the package provided by our XBRL suppliers and those supplied by EBA mainly with regards to geographical breakdown.The problem is regarding total sheets whether these should be included or not and the list of countries that should be reported in the respective sheets. Our XBRL suppliers suggested we contact EBA for further clarification as the instructions and the reference ( please see link below) made in the instructions to Article 96 of the CRR are not clear. The EBA Q&A questions already submitted which refer to geographical breakdown deal mainly with threshold issue, while we need clarifications regarding the list of countries and total sheets. http://www.eba.europa.eu/documents/10180/603236/Draft---ITS-on-reporting_Annexes_Templates.zip For example for table C 15.00 : Extract from Annex IV found in the above link states: “3. Geographical breakdown 9.11. According to Article 96 paragraph 1 second sentence of CRR this template is reported for separately for each property market within the EEA to which the relevant institution is exposed to.”

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 (as amended)

ID: 2014_1019 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 27/03/2014 | Date of publication: 26/09/2014

CR GB 2 - Row 140 – Total exposures

Does the ‘Total exposures’ row in the CR GB 2 template include or exclude ‘Equity’ exposures (row 140)?

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 (as amended)

ID: 2014_959 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 18/03/2014 | Date of publication: 26/09/2014

Publication of administrative penalties

Does the requirement to publish the administrative penalties (Article 68 of Directive 2013/36/EU (CRD)) include publishing supervisory powers listed in Article 104?

Legal act: Directive 2013/36/EU (CRD)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2013_411 | Topic: Other issues | Date of submission: 21/10/2013 | Date of publication: 26/09/2014

Annex XV - Validation formulae and FINREP F 02.00

Validation rule v1699_m {r355} = {r010} - {r090} - {r150} + {r160} + {r200} - {r210} + {r220} + {r280} + {r285} + {r290} + {r295} + {r300} + {r310} + {r320} + {r330} + {r340} - {r350}{r300} is accounting hedge. Moreover the formula includes {r310} which is 'exchange differences net' as well as {r340} which is 'other operating income'. This makes sense as typically 'net operating income= all operating income - all operating expenses' but the dimension hierarchy does not capture this. Accounting hedge [dim:MCY|x4] {r300} and Exchange differences [dim:MCY|x150] {r310} should be under [dim:MCY|x501] in the MCY hierarchy. Secondly even though expenses are reduced from total, they should still be under x501 in our opinion. It looks incorrect to put expenses at the same level as x501.

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 (as amended)

ID: 2014_947 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 14/03/2014 | Date of publication: 26/09/2014

Definition of term "member state"

Within Regulation (EU) No 575/2013 (CRR) there are several Articles using the term "member state" (e.g. Article 4 Paragraph 1 Subparagraph 28, 29, 30, 31, 32, 33, 40, 43, 44, 127 - Article 6 Paragraph 2 - Article 7 Paragraph 1 - ...). Unfortunately neither CRR nor Directive 2013/36/EU (CRD) contain a definition of the term "member state". Can you therefore please provide a definition of the term "member state" especially stressing whether this refers to the states of the European Union or to the states of the European Economic Area?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2013_233 | Topic: Other issues | Date of submission: 11/09/2013 | Date of publication: 26/09/2014

Exemptions from deduction for CET1 items

In Article 48(1)(b) of Regulation (EU) No 575/2013 (CRR) it states: 'where an institution has a significant investment in a financial sector entity, the direct, indirect and synthetic holdings of that institution of the CET1 instruments of those entities that in aggregate are equal to or less than 10% of the CET1 items of the instritution calculated after applying the following:' Question: When making the comparison between the amount of investment and CET1 of the reporting institution, does that comparison refer to the aggregate amount of all significant investments in all financial sector entities OR the comparison should be made on an individual entity basis?

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2013_221 | Topic: Own funds | Date of submission: 09/09/2013 | Date of publication: 26/09/2014

Annex XV Validation rule v0559m does not match the Taxonomy 2.0.1 validation being excuted

Rules Annex XV Rules v0559_m Annex XV The annex lists T1 = C 16.00 a & T2 = C 02.00 What the taxonomy validation is doing Actual validation is taxonomy is referring only to C 02..00 and then checking if same value is same. Issue Validation is not working as it is checking same number

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 (as amended)

ID: 2014_927 | Topic: Supervisory reporting - COREP (incl. IP Losses) | Date of submission: 10/03/2014 | Date of publication: 26/09/2014

Definition of the words "on group basis"

What is the definition of the words “on a group basis” in Article 411 (2) of Regulation (EU) No 575/2013 (CRR)

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2013_192 | Topic: Liquidity risk | Date of submission: 29/08/2013 | Date of publication: 26/09/2014

Interaction between Qualified CCPs and Reporting

Institutions must meet higher capital requirements as long as CCPs are not qualified. Most of the Clearing organisations are working for many years on the derivative market. Will EBA (or national competent authorities) create an interim agreement for that special issue? CCPs are already supervised by their national financial authorities.

Legal act: Regulation (EU) No 575/2013 (CRR)

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2013_177 | Topic: Market infrastructures | Date of submission: 22/08/2013 | Date of publication: 26/09/2014

Annex XV - Validation formulae and FINREP F 05.00

In Report F05.00 - Breakdowns of Loans and Advances by Product, there is validation rule the following validation rule: ID: v0875_m {r080} = sum(r010-070) R080 is using MCY dimension's x469, and R010-070 are using x469's children in MC1 hierarchy, except for R070. R070 is using x226, which is not part of the hierarchy but standalone member in MCY dimension. In addition, x469 has x8 as its children which has nothing to do with it.

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 (as amended)

ID: 2014_924 | Topic: Supervisory reporting - FINREP (incl. FB&NPE) | Date of submission: 10/03/2014 | Date of publication: 26/09/2014