EBA · 2021_6233 Rejected question

Original Maturity for off balance sheet items

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
111 en Annex 1
Topic
Credit risk
Submitted by
Credit institution
Submitted
2021-10-08
Browse ECB SSM Register → More Q&As on this regulation →

Question

1) Are loan commitments that constitute (accepted or unaccepted) loan offers to clients to be considered off balance sheet items, which fall under the definition of 'undrawn credit facilities' of Annex 1?    2) The 'original maturity' that is used for the allocation of 'undrawn credit facilities' to either medium risk, or medium/low risk is determined on the basis of the maturity of the commitment or on the basis of the underlying loan of the offer?

Background

A credit institution has loan commitments for the provision of mortgage loans. The loan commitments relate to mortgage loan offers granted by the institution to clients, and can be either already accepted by the client, or pending acceptance (or refusal) by the client.  The loan offer not yet accepted by the client has a contractual expiry date (typically 45 days) in which the client must either accept or refuse the loan offer, after which the loan offer is cancelled.  The by the client accepted loan offer has a contractual expiry date (typically 4 months) in which the client must take the necessary steps to pass the mortgage act with the notary, after which the accepted loan offer is suspended or terminated (unless an extension is granted by the institution to the client).  The mortgage loan that is the subject of the loan offer has a maturity of (typically) > 20 years.    The maturity of the commitment in the example is 45 days for unaccepted loan offers and 4 months for accepted loan offers, while  the underlying loan of the offer in the example is >20 years).
No answer published yet.

Original source: European Banking Authority, Q&A ID 2021_6233

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.

Similar Q&As

Original maturity for off balance sheet items

Answered 2018-06-08

Original maturity for off-balance sheet items

Answered 2022-02-11

Original maturity of credit lines until further notice

Answered 2022-12-22

Treatment of a loan signed well in advance of a contractually agreed utilisation date (forward starting loan)

Answered 2018-12-21

CCF for uncommitted lines

Answered 2017-11-24

More Q&As on this topic

Application of the currency mismatch treatment to self-employed individuals (natural persons carrying out an economic activity) under Article 123a CRR.

Answered 2026-07-31

Requirements for the purpose of treating exposures secured by mortgages on immovable property as duly secured from an RWA computation perspective under CRR Article 124(2) of the CRR.

Answered 2026-05-08

Use of credit assessments by ECAIs not in scope of Regulation (EC) No 1060/2009.

Answered 2026-03-13

US Hard test: adequacy of considering US charge-off rates corresponding to loss rates for exposures secured by residential property or commercial immovable property situated within the territory of the US

Answered 2026-02-27

Application of the SME definition in specific cases

Answered 2025-11-28

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

Start free trial → Learn more

14-day free trial. No credit card required.