- Question ID
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2016_2698
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
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139
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
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na
- Type of submitter
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Competent authority
- Subject matter
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ECAI ratings
- Question
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1) For the determination of the risk-weight applicable to an exposure, is a “Bank Deposit Rating” an issue rating as per Article 139 of the CRR?
2) For the determination of the risk-weight applicable to an exposure, should a “Bank Deposit Rating” be used instead of an “Issuer rating” for exposures to institutions which are in the form of deposits (i.e. bank deposits)? What would be the treatment in accordance with Article 139 of the CRR?
3) For instance, which Moody’s rating should be used to risk-weight an exposure to an institution which is in the form of a deposit (i.e. bank deposit): - the “Issuer Rating”? - the “Bank Deposit Rating”? - the “Obligation rating”? - one of the other ratings described in Moody’s methodology? Similar considerations apply to ratings issued by other ECAIs.
- Background on the question
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According to Article 139 of the CRR, either the issue rating or the issuer rating should be used for the determination of the risk-weight applicable to an exposure. If an issue rating exists as well as an issuer rating, the issue rating should be preferred (Q&A 652).
Moreover, the Joint Final draft Implementing Technical Standards on the mapping of ECAIs’ credit assessment under Article 136(1) and (3) of Regulation (EU) No 575/2013 published in November 2015 indicates that the following items are mapped for Moody’s: - Global long-term rating scale - Bond fund rating scale - Global short-term rating scale In addition, Annex 22 of the aforementioned ITS (Mapping of Moody’s Investors Service credit assessments under the Standardised Approach, reference JC 2015 067) further specifies that there are only two Moody’s credit ratings which are relevant to risk-weight exposures to institutions: 1) “Issuer Rating” and 2) “Obligation rating”. Nevertheless, the question arises whether “Bank Deposit Ratings” should be used instead of “Issuer ratings” for exposures to institutions in the form of bank deposits because “Bank Deposit Ratings” are also rated on Moody’s Global rating scale.
- Submission date
- Final publishing date
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- Final answer
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Given that for the usage of a credit assessment for the purposes of Article 139 of Regulation (EU) No 575/2013 (CRR) a “Mapping” developed under Article 136(1) CRR needs to exist, any relevant credit assessment used for those purposes has to be accompanied by a Mapping.
For the rules to be used to risk-weight – under the SA to credit risk – an exposure to an institution which is in the form of a deposit (i.e. bank deposit), the institution which is calculating capital requirements should use the relevant provisions outlined in the CRR, taking inter alia into consideration the guidance on the relevant types of credit ratings provided by the ESAs in the context of the ITS on the mapping of ECAIs credit assessments (Regulation (EU) 1799/2016) mandated under Article 136 CRR. The ITS and its supporting documentation do not mention the use of (bank) deposit ratings as issue or issuer ratings, as no mapping is provided to these ratings.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.
- Note to Q&A
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Update 26.03.2021: This Q&A has been reviewed in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR) and continues to be relevant.
Disclaimer
The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.