- Question ID
-
2024_7259
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
-
501a
- Paragraph
-
1
- Subparagraph
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o)
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
-
n.a.
- Type of submitter
-
Competent authority
- Subject matter
-
application of condition specified in Article 501a. (1) o) after January 1, 2025
- Question
-
Are we correct that after January 1, 2025, during the examination of compliance with the ISF factor, it is necessary to examine point o) only in the case of exposures originated after January 1, 2025, and in the case of previous exposures originated before 1 January 2025 the debtor is not obligated to carry out any assessment?
- Background on the question
-
The wording of point o) changes on January 1, 2025. Based on the new wording, the performance of the condition specified in the point o) by the debtor needs to be examined by institutions only in the case of exposures originated after January 1, 2025. In the absence of a transitional provision or other additional rule, based on the change, it is no longer necessary to check compliance with point o) during the ISF compliance examination in case of exposures originated before January 1, 2025, since that point does not apply to previous exposures. Therefore, no assessment shall be carried out by the debtor in the event of exposures originated before January 1, 2025.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because it is considered that EBA guidance or clarification is not needed with regard to the issue that it raises. For example, this can be the case where it is considered that the existing regulatory framework is sufficiently clear and unambiguous, or where different practices may be possible but it is not currently necessary to harmonise these further through the Q&A process.
The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts.
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- Status
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Rejected question