How should IRB-institutions exclude exposures according to art 140.4?

Article 140(4) of Directive 2013/36/EU (CRD) specifies exposure classes relevant for the calculation of institution-specific countercyclical capital buffer rates by reference to Article 112 of Regulation (EU) No 575/2013 (CRR) without reference to the approach for credit risk. Given that Article 112 of the CRR simply lists the different types of exposure classes (in the same way as Article 147 of the CRR), for the application of Article 140(4) of the CRD, one should consider exposure classes of Article 112 irrespective of the method for credit risk calculation under the CRR. The template C 09.03 (CR GB 3) shows the amount which is the basis for the calculation of the institution-specific countercyclical capital buffer. As stated in Q&A 2013_107, the reporting obligation starts in 2014 regardless of the fact that the institution specific countercyclical capital buffer is applicable from 2016 onwards. Please note that, according to Article 162(2) of CRD, the provisions of the institution-specific countercyclical capital buffer in Title VII, Chapter 4 shall apply from 1 January 2016. However, as stated in Article 160(6) and (7) CRD, Member States may impose shorter transitional periods, which could be recognised by other Member States too.