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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

Inconsistency between taxonomy and ITS - MKR SA TDI

In the taxonomy it seems that the following cells may be fed for all exposures classes (In the taxonomy the facts are "open" for the cells of the following rows ) : - row 325 column 610 - row 330 column 610 Bu tin the same time for those cells, the ITS clearly says that " It shall only be reported on Total level of the MKR SA TDI ". So based on the ITS some of our customers do not want to give a split by currency for those cells. => May you confirm if the EBA expects or not to receive a breakdown by currency for the following cells? => Do you thing that the ITS or the taxonomy will be updated accordingly?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_826
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/09/2014

Inconsistency between taxonomy and ITS - report CR SA

In the taxonomy it seems that the cells from the following rows may be fed for all exposures classes (In the taxonomy the facts are "open" for the cells of the following rows ): - 020 : of which SME - 030 : of which : SME subject to SME-supporting factor - 040 : of which : Secured by mortgages ... But in the last version of the ITS (and also in the old one), the functional text mentions that those rows should only be displayed for some specific exposures classes (i.e screen shot below). Some of our customers think that, accordingly to the ITS, the following rows must be "closed" for non listed exposures classes like "Institutions", "central governments or central banks", "Covered Bonds" ... Indeed, for them those reporting SME details for an exposure on "central governments or central banks" is just functional non-sense. => May you confirm that rows "020" to "040" must only be reported for the exposure classes listed in the ITS? => If so, can we expect that a future version of the taxonomy will close the facts relative to those rows for the ITS unlisted exposure classes.

  • 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_825
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/09/2014

COREP NACE codes

Has a revised list of NACE codes been issued or are the current NACE codes based on the Regulation (EC) No 1893/2006 to be used when reporting under COREP?

  • 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_821
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as final Q&A: 05/09/2014

Instructions - Annex II CRSA

We are not clear about how should we report exposures with following combination of exposure class on row 020 and 030 of Total Sheet. Should defaulted exposure to SME (subject to supporting factor ) in Corporate / Retail/ Immovable property , be reported on Total Sheet on Row 020 and 030 ? Should exposure to Corporate SME (subject to supporting factor ) which has been reassigned an exposure class "High Risk", be reported on Total Sheet on Row 020 and 030 as well as "Items associated with particular high risk " ?

  • 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_763
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/09/2014

Reporting of credit risk mitigation on the CR IRB template (C 08.01)

The COREP CR IRB guidelines seem to be conflicting with the validation rules in respect to reporting the substitution effect of Credit Risk Mitigation (CRM), columns 40-80 of the CR IRB template. The instruction for column 040 (Guarantees) is ambiguous, on the other hand it states: "If the CRM effect of the guarantee is calculated by recognition of the substitution effect, the Adjusted Value (Ga) as defined in Article 236 of CRR shall be provided." but also: "When Own estimates of LGD are used: Article 183 of CRR, except paragraph 3. The nominal amount of the guarantees shall be reported." For the substitution approach, the adjusted value of guarantee has to be reported in the column 070 (outflows). The COREP CR IRB template states that the column 070=040+050+060. This formula woud result in the nominal (pre-currency/maturity mismath adjustment) value being transferred from the original obligor's exposure class to the protection provider's exposure class, instead of the adjusted amount. Please clarify which amount is to be reported in the columns 040-050, nominal or adjusted credit protection amounts? In case the answer is different for banks using own LGD estimates and those not, please specify why should this be the case.

  • 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_700
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/09/2014

Validation Rule

Original question: Stimmt die EBA den folgenden validation rules für Tabelle 7 Spalte 100 zu: F07.00 (c100; r060) = F04.04 (c050; r010) bis F07.00 (c100; r180) = F04.04 (c050; r130) Translated question: Does the EBA agree with the following validation rules for table 7 column 100: F07.00 (c100; r060) = F04.04 (c050; r010) to F07.00 (c100; r180) = F04.04 (c050; r130)

  • 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: 2013_606
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Validation Rule

Original question: Stimmt die EBA den folgenden validation rules für Tabelle 7 Spalte 090 zu: F07.00 (c090; r060) = F04.04 (c040; r010) bis F07.00 (c090; r180) = F04.04 (c040; r130) Translated question: Does the EBA agree with the following validation rules for table 7 column 090: F07.00 (c090; r060) = F04.04 (c040; r010) to F07.00 (c090; r180) = F04.04 (c040; r130)

  • 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: 2013_605
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Validation Rule

Original question: Stimmt die EBA den folgenden validation rules für Tabelle 7 Spalten 080 und 110 zu: F07.00 (c080; r060) = F04.04 (c030; r010) bis F07.00 (c080; r180) = F04.04 (c030; r130) F07.00 (c110; r010) = F04.03 (c040; r010) bis F07.00 (c110; r050) = F04.03 (c040; r050) Translated question: Does the EBA agree with the following validation rules for table 7 columns 080 and 110: F07.00 (c080; r060) = F04.04 (c030; r010) to F07.00 (c080; r180) = F04.04 (c030; r130) F07.00 (c110; r010) = F04.03 (c040; r010) to F07.00 (c110; r050) = F04.03 (c040; r050)

  • 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: 2013_604
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Eligibility of subordinated loans for classification as Tier 2 instruments when the rules governing their issue contemplate an obligation of the issuer to repurchase a percentage of them (eligibility limited to the amount of subordinated loans not subject to such repurchase obligation).

Pursuant to the combined application of articles 63 letter k) and 66 letter a) it is correct that a clause – also included in the rules governing the issue of subordinated loans – according to which an issuer is obliged to repurchase a specified amount of subordinated loans does not prevent from classifying such financial instruments as Tier 2 instruments if, in compliance with article 66 letter a), the percentage of subordinated loans that shall be repurchased by the issuer is deducted from Tier 2 items? In other words, a subordinated loans can be classified as Tier 2 instruments if the provisions governing their issue contemplate the undertaking of the issuer to repurchase a specified percentage of the issued subordinated loans provided that - in compliance with article 66 letter a) of CRR - such percentage is deducted from Tier 2 items? The undertaking of the issuer to repurchase part of subordinated loans deriving from the rules governing the issue of such subordinated loans can be considered as a repurchase “contractual obligation” and as a consequence may it fall within one of the cases contemplated under the provisions of article 66 letter a) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1226
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Validation Rule

Original question: Stimmt die EBA den folgenden validation rules für Spalte 070 zu: F07.00 (c070; r010) = F04.03 (c020; r010) F07.00 (c070; r020) = F04.03 (c020; r020) F07.00 (c070; r030) = F04.03 (c020; r030) F07.00 (c070; r040) = F04.03 (c020; r040) F07.00 (c070; r050) = F04.03 (c020; r050) F07.00 (c070; r060) = F04.03 (c020; r060) + F04.04 ((c020./.c030./.c040); r010) F07.00 (c070; r070) = F04.03 (c020; r070) + F04.04 ((c020./.c030./.c040); r020) usw. bis F07.00 (c070; r180) = F04.03 (c020; r180) + F04.04 ((c020./.c030./.c040); r130) Translated question: Does the EBA agree with the following validation rules for column 070: F07.00 (c070; r010) = F04.03 (c020; r010) F07.00 (c070; r020) = F04.03 (c020; r020) F07.00 (c070; r030) = F04.03 (c020; r030) F07.00 (c070; r040) = F04.03 (c020; r040) F07.00 (c070; r050) = F04.03 (c020; r050) F07.00 (c070; r060) = F04.03 (c020; r060) + F04.04 ((c020./.c030./.c040); r010) F07.00 (c070; r070) = F04.03 (c020; r070) + F04.04 ((c020./.c030./.c040); r020) etc. to F07.00 (c070; r180) = F04.03 (c020; r180) + F04.04 ((c020./.c030./.c040); r130)

  • 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: 2013_602
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Own Funds - Subordinated loans as Tier 2 instruments

Our interpretation of Article 63 (g) of the Capital Requirements Regulation (Regulation 575/2013 is that subordinated loans which are perpetual (i.e. do not have a maturity date) would also qualify as Tier 2 instruments under article 63 (g) of the CRR, given that the original maturity would exceed five years (i.e. it would be for an indefinite period). Do you agree with our interpretation? Or is it only subordinated loans with a fixed redemption date (and whose original maturity is of at least five years) which should be recognised as Tier 2 instruments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1220
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Bestimmung der Forderungsklasse von Zentralbanken mit Gesellschaftsform Aktiengesellschaft (EN: Determination of the exposure class for central banks that take the form of a public limited company)

In welche KSA- und IRBA- Forderungsklasse sind die Aktien von (EU- Zentralbanken z.B. Griechenland) einzustufen? EN Translation: In which CRSA and IRBA exposure class are the shares of EU central banks (e.g. Greece) to be classified?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_586
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 29/08/2014

Validations FINREP

Regarding FINREP validations: 1) v779_m / F 01.03: {r090} = {r100} + {r110} + {r120} + {r130} + {r140} + {r150} + {r160} + {r170} + {r180}. Why are {r122} and {r124} not also part of the formula? 2) cell (r90, c90) refers "Conversion of debt to equity", which is disabled for data entry. What is the reason?

  • 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_890
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 22/08/2014

FINREP Template F20.4 (r210,r230)

In template 20.4 row 210 loans to non-financial corporations shall be broken down to “of which: Commercial immovable propertys”. In row 230 loans to household shall be broken down to “of which: loans collateralized by residential”. Are gross carrying amounts of loans formally collateralised by residential or commercial immovable property respectively required in rows 210 and 230? Or shall row 210 include gross carrying amounts of loans that are used to finance commercial immovable properties?

  • 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_864
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 22/08/2014

Definition of assets with an undefined maturity date

May CIU shares which do not meet the requirements of article 416, paragraph 6 of the CRR, but that the institution may call and which are contractually repayable at any time within the 30-day time horizon, be considered as assets with an undefined contractual end and taken into account as inflows up to 20% their total amount?

  • 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_835
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 22/08/2014

Audit of the FINREP figures

1) As regards FINREP reports, audited figures shall mean: - audited FINREP reports (i.e. the external auditor expressing an audit opinion on the FINREP reports as a whole) OR - building the FINREP reports based on final, audited figures existent in the accounting (i.e. based on the information from the annual published consolidated financial statements)? 2) What is the frequency of the auditing obligation in the case of FINREP information?

  • 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_834
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 22/08/2014

Leverage Ratio, form 46.00

In the taxonomy, it seems that we have an open fact set on the cell Line 160 column 02. Although this cell is not mentioned in the ITS (only cells 160;1 and 160;3 seems to appear in the ITS). => May you confirm if the EBA expects or not to receive a fact for cell 160;2? => Will the ITS or the Taxonomy be updated accordingly?

  • 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_827
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/08/2014

Validations

Can the EBA review the attached file which includes specific validations which we believe may be illogical or contain errors. Where appropriate can the EBA amend both Annex XV and the taxonomy. Please note that this is not a repeat of question 2013_524. The attached file contains a further set of validation queries.

  • 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_815
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/08/2014

IIlogical validation in Annex XV

IIlogical validations in Annex XV

  • 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_809
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 22/08/2014

Wrong member in the taxonomy categorization for ‘Type of risk’ dimension in column 040 of template F 13.01

In Report F 13.01 – Breakdown of loans and advances by collateral and guarantees, column 040 (Other collateralized loans – Rest) is interpreted, in the template, as being ‘Collateral other than real estate and other than Cash [Debt instruments issued]’. In this column, for dimension Main category of collateral or guarantees received, all members are being categorized as ‘Other than Real Estate’ while they should be categorized as ‘Other than Real estate, Deposits, Debt securities issued’ thus including other Deposits and Debt securities issued for collaterals other than real estate and being consistent with it’s Hierarchy for collateral received (MC22).

  • 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_789
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 22/08/2014