Which date should apply to the regulatory expected loss for the application of Article 473a(5)(c)?
Pursuant to Article 473a(5) (a) and (b) the reference date is explicitly mentioned not only for the calculation of accounting provisions but also for the regulatory EL. In paragraph 5, the reference to the 01/01/2018 or date of initial application in a narrow reading only relates to the calculation of the accounting provisions and not to the regulatory EL. Which date should apply to the regulatory EL: 31/12/2017, 01/01/2018 or reporting date?
In the absence of an explicit reference date in Article 473a(5)(c) of CRR for the calculation of the regulatory expected loss amounts (EL) in accordance with Article 158(5),(6) and (10) of that Regulation, the reference date for the calculation of the regulatory EL in Article 473(a)5(c) of CRR should be the same as the reference date for the calculation of the IFRS 9 amounts to be reduced, that is 1 January 2018 or the date of initial application of IFRS 9.