EBA · 2024_7055 Rejected question

LCR treatment of a committed facility provided to multiple borrowers

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
460, para. 1
Topic
Liquidity risk
Submitted by
Competent authority
Submitted
2024-04-08

Question

What is the LCR treatment of a committed credit facility provided to multiple borrowers where: each individual borrower might draw the full (undrawn) amount of the committed credit facility; all borrowers belong to the same overarching group which, from group perspective, would qualify as a non-financial corporate; while one or more of the individual borrowers might qualify as a financial customer under Article 411(1) CRR on a stand-alone basis.

Background

The issue at stake is about a committed credit facility provided to multiple borrowers, with all borrowers referred to in such facility belonging to the same overarching corporate group which, from group perspective, would qualify as a non-financial corporate. Each of the individual borrowers might draw the full (undrawn) amount of the facility. While the group as such relates to a non-financial corporate, among the various borrowers, it is understood (also from the clarification provided in the recent email) that multiple entities meet the definition of a financial customer under Article 411(1) CRR on a stand-alone basis. The question is about the LCR treatment of this committed credit facility, namely if the credit institution would need to apply to this facility the outflow rate assumption for a financial customer (on the basis of Article 31(8)(c) LCR DR) or a non-financial (corporate) customer (on the basis of Article 31(4) LCR DR). Applicable rules do not include explicit guidance on the LCR treatment of committed credit facilities where there are multiple borrowers. In general, the outflow rates in the LCR are assumed to reflect the likelihood of various categories or types of liabilities and off-balance-sheet commitments of being run off or being drawn down during a period of idiosyncratic and market-wide stress. The outflow rates conceptually differ between funding providers, also depending on their level of sophistication with financial customers assumed to have quicker and more profound information on the liquidity and funding situation of credit institutions.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2024_7055

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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