EBA · 2019_5031 Rejected question

RWA calculation and the applicable amount of insufficient coverage for non-performing exposures deducted from CET1 items

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
151, para. 1
Topic
Credit risk
Submitted by
Credit institution
Submitted
2019-10-22

Question

Under Article 151(1) CRR, can non-performing exposures, or parts thereof, belonging to one of the exposure classes referred to in points (a) to (e) and (g) of Article 147(2) CRR, be exempted from being risk-weighted to the extent that the related applicable amounts of insufficient coverage for those non-performing exposures have been deducted from Common Equity Tier 1 items, in accordance with Article 36(1) (m) CRR2? Can the applicable amounts of insufficient coverage for non-performing exposures belonging to one of the exposure classes referred to in points (a) to (e) and (g) of 147(2) that have been deducted from CET1 items, in accordance with Article36(1)(m) CRR, qualify as 'exposures deducted from own funds' or 'exposures deducted from Common Equity Tier 1 items, Additional Tier 1 items or Tier 2 items, for the purpose of Article151(1) CRR?

Background

According to Article 151(1) CRR "the risk-weighted exposure amounts for credit risk for exposures belonging to one of the exposure classes referred to in points (a) to (e) and (g) of 147(2) shall, unless deducted from own funds, be calculated in accordance with Sub-section 2 except where those exposures are deducted from Common Equity Tier 1 items, Additional Tier 1 items or Tier 2 items." However, Article 166 CRR under the IRB Approach does not allow for the adjustment of the exposure value for any deductions under Article 36(1)(m) CRR, dissimilar to Article111(1) CRR under the Standardised Approach ("...accounting value remaining after...amounts deducted in accordance with point (m) Article 36(1)..."). Therefore, the question is whether the applicable amounts of insufficient coverage for non-performing exposures belonging to one of the exposure classes referred to in points (a) to (e) and (g) of 147(2) that have been deducted from CET1 items, in accordance with Article 36(1)(m) CRR, qualify as 'exposures deducted from own funds' or 'exposures deducted from Common Equity Tier 1 items, Additional Tier 1 items or Tier 2 items, for the purpose of Article151(1) CRR. Since the exposure value determined in accordance with Article166 CRR is not adjusted for the deduction of Article 36(1)(m) CRR, ensuring inclusion of the deducted amount in the exposure value for the purpose of calculating Expected Loss Amounts, we would expect an adjustment at the level of risk-weighted exposure amounts to avoid additional capital requirements for unexpected losses for (part of) exposures already deducted from CET1.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2019_5031

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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