Response to consultation on Guidelines on proportionate retail diversification methods

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Q1. What is the percentage of exposures within your retail portfolio that are part of a group of connected clients?

Retail exposure value of GCC: 10 475 615,99

Retail exposure value total: 35 799 162,75

Percentage: 29.26%

Q2. Do you identify any implementation issue in implementing the diversification method?

The diversification method itself is not applicable, unless you have at least 500 different retail exposures and for fairly young credit institution this number is hard to achieve in a short period of time.

Q3. Which methods do you currently use to assess retail diversification? Please elaborate.

Currently we are using 75% risk weight for Retail exposures, based on the fact that exposure meet the requirements provided in Article 123 of (EU) No 648/2012)

b) the exposure shall be one of a significant number of exposures with similar characteristics such that the risks associated with such lending are substantially reduced.

In 2024-12-31: We had 283 clients classified as Retail, while the total number of clients are 367 

Since Retail exposures make approximately 77-81% of our total portfolio, the amount of Retail exposures could be considered as “Significant” if we compare it to the total size of our portfolio.

Q4. Under the proposed approach, in the first step of the calculation before any exclusion, what is the share in terms of exposure value of the large eligible retail exposures as defined under the proposed approach compared to all the eligible retail exposures?

Total Retail portfolio: 35 799 162,75

Amount of exposures which are higher than 0.2% of our total Retail portfolio: 31 988 655,61

Which part of portfolio is higher than 0.2% of the total Retail portfolio: 89.36%

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Name of the organization

UAB SME Bank