Reporting of the Undrawn limits of credit cards and overdrafts in F09.01.1 Off-balance sheet exposures: Loan commitments, financial guarantees and other commitments given.

Where to report the Undrawn limits of credit cards and overdrafts? Should the Undrawn limits of credit cards and overdrafts be shown in F 09.01.1 row 10 (Loan commitments given) or in row 170 (Other commitments given)?

According to the instructions, Annex V, Part 2, 113 'Loan commitments' shall be firm commitments to provide credit under pre-specified terms and conditions, except those that are derivatives because they can be settled net in cash or by delivering or issuing another financial instrument. The following items of Annex I to CRR shall be classified as 'Loan commitments': (a) 'Forward deposits'; (b) 'Undrawn credit facilities' which comprise agreements to 'lend' or provide 'acceptance facilities' under pre-specified terms and conditions. In comparison Annex V, Part 2, 115g,h stated that 'Other commitments' shall include the following items of Annex I to CRR: (g) 'Note issuance facilities' (NIFs) and 'Revolving underwritings facilities' (RUFs). (h)'Undrawn credit facilities' which comprise agreements to 'lend' or provide 'acceptance facilities' where the terms and conditions are not pre-specified; Definitions given in Annex V do not indicate unambiguously where to put the Undrawn limits of credit cards and overdrafts correctly, when both options seem possible. We would appreciate the clarification within the Instructions.