5 Q&As on CRR and AMLD: Credit Risk, Customer Due Diligence, Model validation and Central Contact Points (AML/CFT)

The European Banking Authority (EBA) has published the following 5 new Q&As as regards issues relating to the Capital Requirements Regulation (CRR) & Anti Money Laundering Directive (AMLD):
+ 2021_5818 – Central Contact Points (AML/CFT) – Establishment and appointment of a CCP
Do the agents and distributors who are operating in a Member State (MS) or other MSs under the right of establishment based on Article 28 and 29 of PDS2 also fall under the scope of the Delegated Regulation (EU) 2018/1108 and are considered to be establishments (regardless of the way of the operation, distribution, e.g. tied agent or independent distributor, etc. ) under the AML regulation including the Delegated Regulation (EU) 2018/1108?
+ 2021_6048 – Customer Due Diligence – PISP obligations to conduct CDD
In the case where the Payment Initiation Service Provider (PISP) has a business relationship as defined under Article 3(13) of Directive (EU) 2015/849 (AMLD) with the payee, and not with the payer, would it still be considered an occasional transaction for the payer, as the service is provided as a single transaction for the initiation of a payment order from the account that belongs to the payer?
+ 2020_5170 – Credit Risk – Non performing exposures / loan origination – Application of the NPL ratio
Should the calculation of the NPL ratio, as set out in Article 11, paragraph 2 (g)(ii) of the Regulation (EU) 2021/451 only be applicable for the purposes of additional disclosure requirements under Guidelines on disclosure of non-performing and forborne exposures (EBA/GL/2018/10) and additional reporting requirements of NPLs under FINREP, and not for the management of NPLs according to the EBA Guidelines on management of non-performing and forborne exposures (EBA/GL/2018/06)?
+ 2022_6584 – Model validation – Consistency in the treatment of multiple defaults
On 18/3/2022 the Final Draft Regulatory Technical Standards EBA/RTS/2016/03 were published in the Official Journal of the European Union and became legal regulations that take precedence over technical documents (Delegated Regulation (UE) 2022/439). In the light of that, should Banks adopt the same approach for treatment of multiple defaults (so-called symmetrical approach) consistently for all parameters (PD, CCF, LGD) in line with Art. 49 of the aforementioned Commission Delegated Regulation?
+ 2021_5738 – Credit risk – Determination of risk weight for a pass-through SPE exposure with underlying assets where the transaction does not fulfil the conditions for securitisations according to Article 4(1)(61) CRR.
Should an exposure to an SPE transaction with underlying assets and a single class of debt (pass-through structure), which does not fulfil the criteria of Securitisation, be recognised to determine the risk weight of the exposure by applying a look-through approach to the underlying assets as suggested by Article 390(7) CRR regarding large exposures treatment?
Or should such exposure be treated as a (unrated) corporate exposure in accordance with Article 122 CRR?