Treatment of guaranteed export financing transactions under Standardised Approach

Under the Standardised Approach for credit risk, can institutions apply a 0% risk weight to the guaranteed part of export financing transactions if (i) the loan is denominated and funded in the domestic currency of the central government acting as guarantor and (ii) the guarantee is also denominated in this currency while the domestic currency of the borrower is different?

Article 114(4) CRR describes the beneficial treatment of exposures to EU Member States and their central banks, “denominated and funded in the domestic currency of that central government and central bank”. However, it is silent whether this rule can also be applied analogously to guaranteed exposures. Article 235(3) CRR prescribes the following: “Institutions may extend the treatment set out in Article 114(4) and (7) to exposures or parts of exposures guaranteed by the central government or central bank, where the guarantee is denominated in the domestic currency of the borrower and the exposure is funded in that currency.” However, it is not clear whether Article 235(3) CRR describes the only option for guaranteed exposures to achieve a 0% risk weight under Article 114(4) or whether it is a second option besides the analogue application of Article 114(4) CRR to guaranteed exposures. For export financing transactions which are guaranteed by EU central government whose external rating is associated with a 0% risk weight under Article 114 (2) CRR (i.e. the mapping table from credit quality steps to risk weights) do not need to make use of this Article 114 (4) or Article 235 (3) CRR. However, these two articles are relevant for export financing transactions which are guaranteed by EU central government whose external rating does not lead to a 0% risk weight under Article 114 (2) CRR. There are the following two different examples: Example 1: The exposure is (i) denominated and funded in EUR, (ii) guaranteed by the Italian central government and (iii) the guarantee is denominated in EUR while the domestic currency of the obligor is not EUR. In this case, we believe that we apply Article 114 (4) CRR analogously and assign a 0% risk weight since a direct exposure to the Italian government denominated and funded in EUR would receive a 0% risk weight in line with Article 114 (4) CRR. The ultimate risk is towards the Italian central government. Therefore, we can apply Article 114 (4) CRR analogously to guaranteed exposures by requiring that the currency of the guarantee is identical to the domestic currency of the guarantor. Example 2: The exposure is (i) denominated and funded in ZAR, (ii) guaranteed by the Italian central government and (iii) the guarantee is denominated in ZAR while the domestic currency of the obligor located in South Africa is also ZAR. In this case, we believe that we must not apply Article 114 (4) CRR analogously, but can apply Article 235 (3) CRR. Since the guarantee is denominated in ZAR which is identical to the domestic currency of the obligor and the exposure is also funded in ZAR, we can apply a 0% risk weight in accordance with Article 235 (3) CRR.