8 Q&As on CRR, IFR and BRRD

EBA has published the following 8 new Q&As regarding issues relating to the CRR, BRRD and the IFR:
2022_6585 - Leverage ratio – Treatment of reversal features in cash pooling arrangements:
QUESTION: Is a reversal of the daily transfer from the original accounts to the target account, as contractually agreed with the customer, at the next business day compliant with the requirements for net reporting of cash pooling arrangements as set out in Article 429b (2) CRR?
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2022_6602 - Model validation – Estimation of a conversion factor for binding mortgage offers under the IRB Approach:
QUESTION: Is the own estimation of conversion factors for undrawn credit lines considered relevant for binding mortgage offers, with a maturity of less than one year?
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2022_6450 - K-factor requirements – Defining the risk factor for third-country investment firms in K-TCD calculation:
QUESTION: Should the third-country investment firms be classified as investment firms or other counterparties for the purposes of defining the risk factor per counterparty type pursuant to Article 26 IFR?
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2021_5866 - Capital requirements – Qualifying holdings outside the financial sector:
QUESTION: How should the deduction amount of qualifying holdings outside the financial sector, referred to in Article 10(1) IFR, be understood?
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2021_6299 - Liquidity risk – Inclusion of short term deposits in third country credit institutions as liquid assets:
QUESTION: Can unencumbered short-term deposits at third country credit institutions be included in the calculation of liquid assets?
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2020_5342 - Large exposures – „Unexpected outflow“ in the context of applying large exposure exemptions granted in Article 390(6)(c) CRR:
QUESTION: Are the exposures created between service providers, which are caused by clients signing up to new products outside of business hours, an “unexpected outflow” in the context of applying the exemptions granted in Article 390(6)(c) of the Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 (CRR2)?
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2022_6588 - MREL – MREL determination in case of an entity that is subject to simplified requirements in respect of resolution plan:
QUESTION: In case of an entity that applies simplified requirements (according to which the resolution plan is updated every 2 years) how is MREL determined/decision taken?
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2023_6716 - Credit risk – Treatment for strategic long-term non-listed equity exposures under simple risk weight approach as per Article 155(2) CRR:
QUESTION: Can a RW of 190% be applied to long-term strategic investments in non-listed equity exposures as per Article 155(2) CRR, provided that they are in a sufficiently diversified portfolio?