Question 1: One or more senior officers of a bank, ideally at board level or equivalent, should attest in writing that Pillar 3 disclosures have been prepared in accordance with the board-agreed internal control processes.For banks of foreign branches, is Country Manager or CFO at Head office attestation sufficient?
For local banks and large foreign banks, Board member attestation will be expected. For smaller foreign bank branches, Country Manager/GM will be sufficient

Question 2: There are requirements on the Pillar III disclosure that is dependent on the BASEL returns (BRF 95), in relation to this, the submission that mentions 6 weeks after the end of the relevant quarter starts from the BASEL quarter reporting deadline or actual quarter end?
Pillar 3 disclosure submission will be 6 weeks after the quarter end date. For example, December quarter submission will be 6 weeks from December 31^st and not 6 weeks from January 31^st. Since the BRF95 should mandatorily be submitted by banks within 4 weeks from quarter end, the bank still has additional 2 weeks to complete the Pillar 3 disclosures based on BRF95.

Question 3: Pillar 3 applies to all banks in the UAE at the top consolidated level for local banks...Please clarify in case of subsidiary of a bank, whether revised pillar 3 disclosures will be required to be prepared at consolidated Group level or stand-alone level?
Bank subsidiaries will be consolidated at stand-alone subsidiary level and the group bank will be consolidated at the stand-alone of the group bank only without the bank’s subsidiary data.

Question 4: Pillar 3 disclosures can be presented in a separate report; however, Can it be signposted to the audited financial statements?
Signposting is allowed if the bank chooses to use the same template in their audited financial statements but a separate reporting template needs to be prepared as per Pillar 3 templates which is mandatory and cannot be omitted from the Pillar 3 tables.

Question 5: If any section/ table of Template is not applicable to the Bank (i.e.DSIBs, Securitisation), shall the Bank exclude this section/ table completely irrespective of type of table.
Yes, banks can exclude the tables/templates not pertaining to the bank, for example DSIB and Securitisation

Question 6: Banks should also have a formal board-approved disclosure policy for Pillar 3 information that sets out the internal controls and procedures for disclosure of such information.Should this formal Disclosure policy still be submitted to Central Bank along with ICAAP or it shall only be published / disclosed as mentioned?
The formal disclosure policy should not be submitted but should be available on request by Central Bank of UAE.

Question 7: Will it be sufficient to publish Basel 3 disclosures on its investor relations page on the bank’s website without any physical printouts?
Banks should publish their Pillar 3 report in a stand-alone document on the bank’s UAE-specific website. This can be anywhere on the website but it needs to be clearly visible and easily available for all stakeholders. Banks which do not have a UAE-Specific website should create a website specific to UAE so that all stakeholders can have access to the Pillar 3 disclosures of the bank.

Question 8: For REM1 template, is Central Bank expecting the Bank to report overseas earnings or only the locally paid compensation? Are deferrals awarded in the current year only to be reported? If an employee has a deferral which has a tranche of a prior year paid out after they have left the Branch, is it expected that this would be reported or not? If a prior year tranches awarded is reported should this be reported if the individual is no longer an employee of the Branch?
All contract earnings of all employees need to be reported even if the employee is earning compensation in UAE and outside UAE. The full contractual award needs to be mentioned and not only the physical payout

Question 9: Is the End of Service Benefit (EOSB) i.e.severance payment for a normal leaver to be reported depending upon the definition of “other material risk taker” OR are banks also required to report any additional payment such as a redundancy type payment? Should a transfer of Senior Management personnel or Other Material Risk-takers to other branch of the Bank be considered as severance for reporting purpose?
All payments regardless of the type of payment based on the contract needs to be reported

Question 10: For branches of foreign banks where the Head Office reports to the home regulator, there are pre-fixed formats prepared and submitted at a frequency as stipulated by home regulator.Can the branch of foreign banks provide such reports in UAE which are submitted to the home regulator as a part of UAE Pillar 3 Disclosures?
Reports sent between Head Office and UAE needs to be separated and only the Pillar 3 disclosures as per this Guidance needs to be reported for UAE branches in the mandatory formats published here.

Question 11: What does “Fully loaded” ECL accounting model mean and what is the difference between total capital and fully loaded capital?
"Fully Loaded" means bank’s regulatory capital compared with a situation where the transitional arrangement had not been applied

Question 12: For branches of foreign banks, would Central Bank allow for a transition period if the threshold for partial disclosure is reached? (i.e.if RWA exceed AED 5 billion)
Transition will be granted on a case by case basis

Question 13: Currently CCyB buffer is 0% in UAE.In this case, what do banks need to report in CCyB template?
Currently CCyB is not applicable in UAE but if banks in UAE have branches in other countries this needs to be reported if CCyB is being reported as per that foreign country’s regulations. Banks, hence, need to calculate and fill the CCyB1 as explained in the Capital Supply standards.

Question 14: In Sheet CR5, for "Unrated" Category, should we include the Post CRM and CCF amounts in their respective Risk Weight categories or should we club it under "Others"?
Yes, it can be placed in “Others” along with any other ratings.

Question 15: In Sheet OV1, is the minimum requirements simply 10.5% of the RWA.
Pillar 1 capital requirements at the reporting date will normally be RWA*10.5% but may differ if a floor is applicable or adjustments (such as scaling factors).

Question 16: CCR8 requires Bank to report Exposures to Non QCCPs (excluding initial margin and default fund contribution) arising of (i) OTC derivatives, (ii) Exchange-traded derivatives, (iii) Securities financing transactions & (iv) Netting sets where cross-product netting has been approved.Does this mean the Exposures computed under SA-CCR which are eligible under Netting Jurisdiction to be disclosed under (iv)?
Currently, UAE has no netting jurisdiction but such exposures reported will be taken into consideration on a case-by-case basis.

Question 17: LIQA, Liquidity exposures and funding needs at the level of individual legal entities, foreign branches and subsidiaries, taking into account legal, regulatory and operational limitations on the transferability of capital.Are insurance or non-bank subsidiaries to be included?
All entities that are consolidated by the bank must be included.

Question 18: LIQA, Balance sheet and off-balance sheet items broken down into maturity buckets and the resultant liquidity gaps.Is there any format for reporting the liquidity gap report?
As per BRF 9 reported by the bank. The bank may add a section for Off Balance sheet as required