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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.

List of Q&A's

Liquidity: Instructions on reporting outflows in relation to custody, clearing and cash managment

Are the references to the Basel rules correct? Looking at the January 2013 Basel document, paragrapphs 75 and 76 referred to in the instructions do not appear to be the relevant in this context, as they refer to stable retail deposits.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

FINREP Reporting for firms with Accounting Reference Date other than 31 December

Article 18 (3) confirms that FINREP applies from 1 July 2014. We have a financial year end of 30 September which means that where we will report our first quarter's data for relevant templates (in full) as at 30 September 2014. For semi-annual templates should we only report a quarter's data in our first submission (1 July to end September) or should we start collecting data from 1 October, and report a full 6 months of data as at 31 March 2015? For annual templates should we only report a quarter's data in our first submission (1 July to end September) or should we start collecting data from 1 October, and report a full year's data as at 31 March 2015? The period 1 July 2014 to 30 September 2014 is a full quarter, so this will allow us to report a full quarter's data.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

COREP CA1: Reference to CRR Art 3 is unclear

CA1 Row 524 Column 010 relates to Article 3 of CRR. Article 3 of CRR, relating to Application of stricter requirements by institutions states: "This Regulation shall not prevent institutions from holding own funds and their components in excess of, or applying measures that are stricter than those required by this Regulation. Can the EBA please confirm if this relates to the difference between Capital Requirement and Capital Holdings? Alternatively is this cell intended to reflect any additional capital holding dictated by competent authorities?

  • 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)

Leverage ratio: Exposure value of derivatives

Article 429.6 of Regulation (EU) No 575/2013 (CRR) states that the exposure value of financial derivatives listed in Annex II and of credit derivatives shall be calculated in accordance with the Mark-to-Market method (see Art. 274 of CRR). Based on such instructions, it is not clear if the above mentioned method shall be applied both to OTC and exchange trade derivatives, also including those contracts cleared with CCPs.

  • 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)

COREP: 'residence of the obligor' for the purposes of the CRGB1 template for supranational organisations and multilateral development banks

The guidelines for the CR GB 1 COREP template, Geographical breakdown of exposures by residence of the obligor, state that 'residence of the obligor' refers to the country of incorporation. However, how is this guideline to be applied in the case of exposures to either supranational organisations such as the EU (European Union) or multilateral development banks such as the EIB (European Investment Bank)?

  • 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)

Remittance dates in case of an accounting year-end which deviates from the calendar year

Is our understanding that submission of "financial information" based on their accounting year-end which deviates from the calendar year is relevant to FINREP templates only, but not to wider financial and prudential information (incl. COREP, LE, LR, LCR...) as well, 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)

FINREP: Counterparty classification of European institutions

This question ask for a clarification of the classification of European institutions into counterparty sectors for financial information templates (FINREP) foreseen by EBA FINAL draft implementing Technical Standards 2013-02, Anex V, Part 1. Counterparty breakdown across all templates shall align with ECB statistical requirements ECB/2008/32. In Regulation (EU) No 549/2013 of the European Parliament and of the council of 21 May 2013 on European system of national and regional accounts in the European Union, in paragraph 19.12. is stated that “The European Investment Bank and the European Investment fund are separate institutional units classified in the “Other financial intermediaries, except insurance corporations and pension funds” subsector (S.125) of the “financial corporations” sector (S.12)”. 1) Does FINREP follow this Regulation (EU) No 549/2013 in case of The European Investment Bank and the European Investment fund classification? 2) What counterparty sector for purpose of FINREP is the European Financial Stability Facility classified into? 3) Is there any list of European institutions including information about its counterparty sectors for purposes of FINREP available?

  • 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)

FINREP: Definition of Credit institutions and Other financial corporations

This question asks for a clarification of the definition of Credit institutions (bank and multilateral banks) and Other financial corporations for financial information templates (FINREP) foreseen by EBA FINAL draft implementing Technical Standards 2013-02 published on 26 July 2013, Anex V, Part 1. Counterparty breakdown across all templates shall align with ECB statistical requirements ECB/2008/32. The Article 1 of that ECB regulation provide us with definition of MFI and breakdown of MFI to a) central banks, b) credit institutions as defined in Article 4(1) of Directive 2006/48/EC and c) other MFIs (e.g. Money market funds). For purpose of FINREP it is not clear if c) other MFIs (e.g. Money market funds) as defined in ECB Regulation shall be classified as Credit institutions sector (bank and multilateral banks) or Other financial corporations sector.

  • 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)

Large exposures: LE4 and LE5 on maturity buckets for institution's and unregulated entities applies to firms reporting on solo basis.

Do COREP templates LE4 and LE5, which contains the maturity structure of 10 largest exposures to unregulated financial entities apply to an entity reporting on solo basis?

  • 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)

Large exposures: Definitions of ‘institutions’ for the purpose of the LE reporting

‘Investment funds’ is not a defined term within Article 4 of Regulation (EU) No 575/2013.

  • 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)

FINREP - template F14 changes for the period

Are changes relevant "for the period" to be reported year-to-date (YTD) or only of the last quarter?

  • 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)

FINREP Loan commitments, financial guarantees and other commitments received

How shall off-balance sheet exposures be reported in first FINREP reports if the data is not available in the accounting systems? Can a starting date for collecting this dta be set?

  • 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)

FINREP - template F. Loans and advances by product, by collateral and by subordination

How shall breakdown of loans according to product, collateral and subordination be reported if collateral information is not available to together with product?

  • 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)

FINREP - template F7 Accumulated write-offs

How shall accumulated write-offs be reported in the first reporting reference dates when all data may not be available?

  • 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)

FINREP Past due but not impaired < 30 days

Can materiality thresholds be applied when reporting "technical" past due 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)

FINREP Amount of cumulative changes in fair value due to credit risk

In the absence of accurate information how the amount of cumulative changes in fair value due to credit risk should be reported? This question is also relevant for templates F4.2, F8.1, F16.5, F45.1.

  • 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)

FINREP, interim dividends

What amount should be reported on row 260 of template F1.3, the dividends distributed during the year or the proposed dividends for the financial year?

  • 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)

IP Losses: Direct and Indirect costs associated with immovable property losses

In relation to direct and indirect costs associated with immovable property losses can the EBA please confirm what costs should be included?

  • 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)

FINREP: thresholds applicable to F20.1 - 20.7 (geographical breakdown)

How to interprete the threshold for FINREP templates 20.1 till 20.7: - link in article 5a(4) to COREP table 4 seems not correct; - is the threshold domestic/non domestic applicable for all templates 20.x? - if the threshold is per table: what with annexes 20.4 - 20.7? is the threshold applicable per country of the counterparty?

  • 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)

COREP: CA5.1 Template (Rows 133, 136 and 138)

With the addition of Rows 133, 136 and 138 into the CA 5.1 template we seek clarification on whether or not these are sub-sets of other Rows, or standalone.

  • 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)