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Breadcrumb

  1. Home
  2. Single Rulebook Q&A
  3. 2019_5031 RWA calculation and the applicable amount of insufficient coverage for non-performing exposures deducted from CET1 items
Question ID
2019_5031
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Credit risk
Article
151
Paragraph
1
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
Not applicable
Type of submitter
Credit institution
Subject matter
RWA calculation and the applicable amount of insufficient coverage for non-performing exposures deducted from CET1 items
Question
Under Article 151(1) CRR, can non-performing exposures, or parts thereof, belonging to one of the exposure classes referred to in points (a) to (e) and (g) of Article 147(2) CRR, be exempted from being risk-weighted to the extent that the related applicable amounts of insufficient coverage for those non-performing exposures have been deducted from Common Equity Tier 1 items, in accordance with Article 36(1) (m) CRR2? Can the applicable amounts of insufficient coverage for non-performing exposures belonging to one of the exposure classes referred to in points (a) to (e) and (g) of 147(2) that have been deducted from CET1 items, in accordance with Article36(1)(m) CRR, qualify as 'exposures deducted from own funds' or 'exposures deducted from Common Equity Tier 1 items, Additional Tier 1 items or Tier 2 items, for the purpose of Article151(1) CRR?
Background on the question
According to Article 151(1) CRR "the risk-weighted exposure amounts for credit risk for exposures belonging to one of the exposure classes referred to in points (a) to (e) and (g) of 147(2) shall, unless deducted from own funds, be calculated in accordance with Sub-section 2 except where those exposures are deducted from Common Equity Tier 1 items, Additional Tier 1 items or Tier 2 items." However, Article 166 CRR under the IRB Approach does not allow for the adjustment of the exposure value for any deductions under Article 36(1)(m) CRR, dissimilar to Article111(1) CRR under the Standardised Approach ("...accounting value remaining after...amounts deducted in accordance with point (m) Article 36(1)..."). Therefore, the question is whether the applicable amounts of insufficient coverage for non-performing exposures belonging to one of the exposure classes referred to in points (a) to (e) and (g) of 147(2) that have been deducted from CET1 items, in accordance with Article 36(1)(m) CRR, qualify as 'exposures deducted from own funds' or 'exposures deducted from Common Equity Tier 1 items, Additional Tier 1 items or Tier 2 items, for the purpose of Article151(1) CRR. Since the exposure value determined in accordance with Article166 CRR is not adjusted for the deduction of Article 36(1)(m) CRR, ensuring inclusion of the deducted amount in the exposure value for the purpose of calculating Expected Loss Amounts, we would expect an adjustment at the level of risk-weighted exposure amounts to avoid additional capital requirements for unexpected losses for (part of) exposures already deducted from CET1.
Submission date
22/10/2019
Rejected publishing date
11/02/2022
Rationale for rejection

Please note that as part of adjustments to the Single Rulebook Q&A process, agreed by the EBA and the European Commission, it has been decided to reject outstanding questions submitted before 1 January 2020, when the Q&A process was updated as part of the last ESAs Review. In particular, the question that you have submitted has now regrettably been rejected and will not be addressed.

If you believe your question would still benefit from clarification, you are invited to resubmit your question, adapting it to reflect any legislative, regulatory or other relevant developments that may have occurred since the initial date of submission. The EBA will aim to address resubmitted questions as a matter of priority. When considering to resubmit, you are kindly requested to observe the updated admissibility criteria agreed in the context of the adjustment of the Q&A process, available in the Additional background and guidance for asking questions. We hope for your understanding.

For further information please refer to the press release and the updated Q&A page.

Status
Rejected question

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