EBA · 2024_7259 Rejected question

application of condition specified in Article 501a. (1) o) after January 1, 2025

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
501a, para. 1
Topic
Credit risk
Submitted by
Competent authority
Submitted
2024-11-27
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Question

Are we correct that after January 1, 2025, during the examination of compliance with the ISF factor, it is necessary to examine point o) only in the case of exposures originated after January 1, 2025, and in the case of previous exposures originated before 1 January 2025 the debtor is not obligated to carry out any assessment?

Background

The wording of point o) changes on January 1, 2025. Based on the new wording, the performance of the condition specified in the point o) by the debtor needs to be examined by institutions only in the case of exposures originated after January 1, 2025. In the absence of a transitional provision or other additional rule, based on the change, it is no longer necessary to check compliance with point o) during the ISF compliance examination in case of exposures originated before January 1, 2025, since that point does not apply to previous exposures. Therefore, no assessment shall be carried out by the debtor in the event of exposures originated before January 1, 2025.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2024_7259

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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