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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

Trading desk requirements for Standardized approach perimeter

Could you please confirm whether all desks in the prudential perimeter, independently from the internal model or standardized approach, should respect the requirements for trading desks reported in Article 104b and other provisions for trading desks?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7076
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Trading and Banking book positions within a Trading desk

Could an A-IMA eligible Trading desk have trading and banking book positions segregated in different portfolios within the same desk, given that non-trading book positions are carve-out from A-IMA calculations?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7075
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Classification of Repo Transaction

How can internal repo transactions be managed in the calculation of the regulatory capital requirement in the A-IMA trading desk? Can these transactions be carved out from the scope of regulatory capital requirement of the A-IMA trading desk? Does the regulation prescribe that the funding in repos should be allocated to the trading/banking book accordingly to the funding strategy purpose? (if the funding is for banking book positions, the repos are non-trading instruments, if the funding is for trading book strategy the repos are trading book instruments). Is it possible to have different prudential classification of internal repos and external repo transactions on the market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7074
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Treatment of two-leg derivatives with respect to rate type and currency

What is the expected representation for two-legs derivatives in the templates "BREAKDOWN OF SENSITIVITY ESTIMATES (J 02.00, J 03.00 and J 04.00)" and REPRICING CASH FLOWS (J 05.00, J 06.00 and J 07.00)?

  • 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
  • ID: 2024_7073
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

Reporting Requirements per type of institution

Are small and non-complex/other institutions required to use the simplified set of templates, or can they use the Large format if they already have to produce it, for example, for their holding/parent company?

  • 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
  • ID: 2024_7072
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Prudential Classification of Repo Transaction

What treatment for market risk capital requirement should be adopted for repos included in an A-IMA trading desk where those repos are used for funding of trading positions and valued at accrual and thus excluded from the regulatory trading book, following Basel Committee’s provision?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7071
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Level of application of permissions for consolidated netting

How should the term “consolidated basis” be read? Should such permissions be granted only to the highest EU consolidated entity or is it possible to grant these permissions also to several EU sub-consolidated entities? If it is possible to apply this requirement also on sub-consolidated basis, should the netting of the positions only refer to undertakings included in such entity’s sub-consolidating group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7058
  • Topic: Market risk
  • Date of submission:

LCR treatment of a committed facility provided to multiple borrowers

What is the LCR treatment of a committed credit facility provided to multiple borrowers where:each individual borrower might draw the full (undrawn) amount of the committed credit facility;all borrowers belong to the same overarching group which, from group perspective, would qualify as a non-financial corporate; whileone or more of the individual borrowers might qualify as a financial customer under Article 411(1) CRR on a stand-alone basis.

  • 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
  • ID: 2024_7055
  • Topic: Liquidity risk
  • Date of submission:

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
  • ID: 2024_7053
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 03/05/2024

Interest flows

Interest flows for retail on sight accounts (without contractual maturity)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7052
  • Topic: Liquidity risk
  • Date of submission:

Definition of Financial Institution / Third Country Undertakings

Should the definition of "Financial Institution" as used in IFR be interpreted as excluding firms established in third countries unless otherwise expressly stated?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7045
  • Topic: Prudential consolidation
  • Date of submission:
  • Published as Rejected Q&A: 26/04/2024

ESG P3 - Template 5 validation rule v12726_m

Is the validation rules v12726_m correctly defined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7041
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/04/2024

Alternative arrangements for variable remuneration in investment firms

Can the use of alternative arrangements for the payment of variable remuneration be approved where the use of instruments under art 32(1)(j) IFD is theoretically possible but might endanger the stability of the investment firm?

  • Legal act: Directive (EU) 2019/2034 (IFD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/14 - Guidelines on internal governance under Directive (EU) 2019/2034
  • ID: 2024_7040
  • Topic: Remuneration
  • Date of submission:

Applicability of the EUR 500 million-limit when calculating the required stable funding associated with CIUs in NSFR

Does the EUR 500 million-limit for the integration of CIUs in the liquidity buffer composition requirement indicated in article 15.1 of the LCR delegated act 2015/61 also apply to the CIU RSF in NSFR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7039
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2024

Val rules_v12727_m_for template 7 GAR amount is not aligned with ITS

We believe the ITS instructions 2022/2453  are incorrect for Row 32 into ITS (EU) 2022/2453. NB =  equivalent row into DPM is 0320.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7038
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/04/2024

Management of the Trading Book - Active Anti-Fraud Procedures and Controls

Under Article 103(2), point (b)(vi), CRR, there is a requirement that institutions shall have active anti-fraud procedures and controls. Could you please provide clarification on the specific types of fraud that should be considered with respect to the trading book? Can this be considered to effectively cross-refer to the requirements of Regulation (EU) No 596/2014 on market abuse or are there other areas which need to also be considered?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7037
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 04/04/2024

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
  • ID: 2024_7036
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 05/04/2024

Modelling the risk of migration from NMDs to term deposits in the context of the constant balance sheet assumption in the NII SOT.

Is it modelling the risk of migration from NMDs to term deposits consistent with the constant balance sheet assumption in the NII SOT?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities
  • ID: 2024_7035
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

Disclosure of exposures arising from Article 390 (5)

How the exposures as per Article 390 (5) be reported in Corep templates C28 & C29 - direct vs indirect?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7031
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2024

Credit derivatives on CLO in SA-CCR

Should a credit derivative with underlying a CLO (Credit Loan Obligation) be treated as multi-name under Article 280c(1) because the underlying is a pool of loans or single name because the issuer is unique, SPV, or can the tranche be viewed as a whole?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7030
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/04/2024