- Question ID
-
2025_7311
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Credit risk
- Article
-
124
- Paragraph
-
1
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
-
n/a
- Type of submitter
-
Credit institution
- Subject matter
-
Identification of the part of the exposure not covered by the lien on the property
- Question
-
To identify the part of a non-ADC-exposure that shall be treated as stated in Article 124(1), which amount of the exposure has to be compared to the nominal amount of the lien?
- Background on the question
-
Article 124(1) states, that any part of a non-ADC-exposure that exceeds the nominal amount of the lien on the property, shall be risk weighted as an exposure to the counterparty not secured by this property in case of a non-IPRE exposure or it shall be assigned a risk weight of 150 % in case of an IPRE exposure.
We assume that the calculation, which amount associated with the exposure exceeds the amount of the lien, is to be done using the exposure value as defined in Article 111 - is this correct?
Example:
IPRE exposure with an amount owed of 900 000 EUR (= accounting value) and an undrawn but committed amount of 250 000 EUR (classified as item in bucket 3 according to Annex I); there is a mortgage on a residential property; the amount of the lien is 1 000 000 EUR, and the property value is 1 300 000 EURThe exposure value of the exposure is therefore 900 000 + 250 000 * 0,4 = 1 000 000 EUR
Thus, there is no part of the exposure exceeding the amount of the lien on the property based on the exposure value.
Note: There was a Q&A on a related topic regarding Article 125(2) of CRR before amendment by Regulation (EU) 2024/1623 - question ID 2014_705.
We reckon, under the amended version of CRR, the exposure value calculated in accordance with Article 111 is the base to determine, which part of the exposure shall be assigned a risk weight of 20 % or 60 % respectively under Articles 125(1) and 126(1) and how high the remaining part of the exposure referred to in the last sentence of these paragraphs is.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the matter it refers to is in the process of being answered in Q&A 7422.
- Status
-
Rejected question