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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

Application of the retention requirements to situations where the retained exposure is transferred to a third-party after losses associated with the relevant exposure

Can a retention holder under Article 6(3)(c) (so-called random selection) of Regulation (EU) 2402/2017 (“Securitisation Regulation”) transfer the retained exposure to a third party if the transfer occurs after crystallisation on the retention holder’s accounts of the losses associated with the relevant exposure?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Risk retention obligation in case of voluntary liquidation of an Alternative investment fund (“AIF”) acting as retention holder under Article 6(3) of the Securitisation Regulation

Assuming an alternative investment fund (“AIF”) set up to disburse loans to be subsequently securitised acts as retention holder under Article 6(3) of Regulation (EU) 2402/2017 (hereinafter, the “Securitisation Regulation”), should it be resolved to voluntarily liquidate the relevant AIF, what would be the appropriate modality to continue to retain the relevant net economic interest? Would the retained net economic interest be distributed to AIF’s unit-holders, pro quota to their holdings, or would AIF’s liquidator be obliged to wait and complete the liquidation process only after the retention obligation has ceased to exist?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

LCR treatment of open maturity reverse repos which can be terminated at any point in time

By reference to EBA Q&A 2021_6163, are there some circumstances under which a bank could consider inflows from open reverse repos that  are not contingent for the purposes of its recognition in the LCR? 

  • 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

Vega and curvature risk requirements for positions in instruments without exercisable optionality that are sensitive to vega risk factors

Should only instruments that are options be subject vega and curvature own funds requirements, or they may apply also to instruments that lack an exercisable optionality?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Other assets/liabilities in the context of NSFR templates (C 80.00 and C 81.00)

Should institutions report as Other Assets or Other Liabilities also the IFRS accounting corrections deriving from the adoption of a macro-hedging strategy on Interest Rate Risk? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

C14.00 - v7364_m - Type of Assets (column 0160)

The EBA Validation Rule v7364_m states that: For securitization programs qualified for differentiated capital treatment and classified as traditional (and Non NPE), synthetic or ABCP, then the asset class of the portfolio (C14.00 - c0160) must be “Loans to SME (treated as corporate)” or “Loans to SME (treated as retail). Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

Template C 14.00 - Validation rule v11661_m - ({C 14.00, c0231} >= {C 14.00, c0251}) or ({C 14.00, c0265} >= {C 14.00, c0251}) - If value missing (but table prerequisites met) “treat as zero/empty string”, Template C 13.01 – Validation rule v7430_m - {c0710} = {c0720} + {c0740} + {c0760} + {c0830} + {c0850}

Range of applicability of validation rules v11661_m and v7430_m in force starting from June 2023 with DPM 3.2.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

Loan collateralized by commercial/residential immovable property in CRR Pillar 3 Template 2 and Template 5

What should be included in the line item "loan collateralized by commercial/residential immovable property" in CRR Pillar 3 Template 2 and Template 5?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Reference of the cells and reports layouts to use for the public disclosures (NOT the XBRL reporting)

Question 1: What are the cells references that must be publicly disclosed into annual and semiannual public disclosures: the reference of the cells from the ITS or the references of the cells from the XBRL? Question 2: What are the reports layouts that must be publicly disclosed into annual and semiannual public disclosures: the layout from the ITS or the layout from the XBRL?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 1 - exposures towards companies excluded from EU Paris-aligned Benchmarks

Should the EU Paris-aligned Benchmarks exclusion criteria be applied at consolidated group level and to that end, exclude the total gross carrying amount of the exposure towards the consolidated group level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

In relation to the minimum ‘list of NACE sectors to be considered’ in template 3, when detailed assumptions/ specific scenarios are not available on the IEA website for one of the NACE codes included in the “the minimum ‘list of NACE sectors to be considered’” (e.g. 29.32 Manufacture of other parts and accessories for motor vehicles), should it be left blank in the template?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 2 - EBA val rules and Column 0160 Of which level of energy efficiency EP score in kWh_m of collateral estimate

Question 1: Are the validation rules v16092_m; v16090_m; v16088_m; v16086_m; v16084_m;v16082_m; v16080_m; v16078_m; v16049_m correctly defined?    Question 2:  How to deal with exposure for which and EPC is available, but the Level of energy efficiency (EP score in kWh/m² of collateral) is absent from the EPC?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Permission to reduce AT1, Tier 2 or eligible liabilities instruments and deduction rules in the context of a liability management exercise without replacement.

When should deductions from own funds and eligible liabilities be applied in the context of a liability management exercise without replacement (i.e. a tender offer)? When can the unredeemed part of own funds or eligible liabilities be included in own funds or eligible liabilities again?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

1.           Should the year of reference column refer to the year for which the latest emission intensities are available for a specific sector included in the template? 2.           Could you please confirm if alignment metrics should be calculated based on actual gross carrying amount (column c) in combination with the latest emission intensity information that is available for the specific sector?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Sum of breakdowns in Template 1 (financed emissions)

Should the sum of NACE sub-sectors for GHG financed emissions in columns i and j of Template 1 be equal to the total GHG financed emissions for that NACE sector?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 1 – Equity instruments

The instructions state “Institutions shall disclose the gross carrying amount, referred to in Part 1 of Annex V to Implementing Regulation (EU) 2021/451, of those exposures towards non-financial corporates, including loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading or held for sale assets”.In this case, should the definition of equity instruments also include investments in subsidiaries, joint ventures and associates, or should entities consider the definition of accounting portfolios of financial instruments provided by Annex V of FINREP, which specifically excludes investments in subsidiaries, joint ventures and associates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Disclosure of transactions with zero exposure value

Under Article 274(5) and 273 there are circumstances where transactions may have a zero exposure value e.g. netting sets made up entirely of written options or certain CDS transactions. Should these be reported in the C34.02 with values in columns 0020-0140 and then have c0150 onwards set to 0 (or c0170 onwards?) or should they be disregarded from population of values in any columns as there is no requirement to calculate exposure for these transactions. Similarly should they be included in the same C34.03 columns?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions

ITS ESG P3 - Template 2 - Should loan/collateral ratio (loan-to-value) be taken into account?

We have interpreted column a in Template 2 to be filled in with the gross carrying amount of the loan collateralized with commercial and residential immovable property and of repossessed real estate collaterals. What if the collateral value is less than the gross carrying amount of the loan? Should we in this case fill in the gross carrying amount of the loan or use the amount of the loan that is actually collateralized with commercial/residential immovable property in Template 2? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Discrepancy between definition of ‘investment holding company’ and ‘consolidated situation.’

Could a financial institution the subsidiaries of which are mainly tied agents or ancillary services undertakings, but which also has at least one investment firm as subsidiary, be considered an  investment holding company as referred to in Article 4(1)(23) IFR?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Minimum loss coverage for non-performing exposures under Article 469a

In case a default occurred on a debt obligation originated before 26 April 2019, and if the originating bank grants the defaulted obligor a forbearance measure in the form of a partial refinancing of a debt obligation to cover past due payments on the original debt obligation and thus effectively increases the bank’s total exposure towards the obligor, will the original debt obligation, which has not been increased, cease to be subject to the derogation provided for in Article 469a(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable