EBA · 2025_7311 Rejected question

Identification of the part of the exposure not covered by the lien on the property

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
124, para. 1
Topic
Credit risk
Submitted by
Credit institution
Submitted
2025-01-22

Question

To identify the part of a non-ADC-exposure that shall be treated as stated in Article 124(1), which amount of the exposure has to be compared to the nominal amount of the lien?

Background

Article 124(1) states, that any part of a non-ADC-exposure that exceeds the nominal amount of the lien on the property, shall be risk weighted as an exposure to the counterparty not secured by this property in case of a non-IPRE exposure or it shall be assigned a risk weight of 150 % in case of an IPRE exposure. We assume that the calculation, which amount associated with the exposure exceeds the amount of the lien, is to be done using the exposure value as defined in Article 111 - is this correct? Example: IPRE exposure with an amount owed of 900 000 EUR (= accounting value) and an undrawn but committed amount of 250 000 EUR (classified as item in bucket 3 according to Annex I); there is a mortgage on a residential property; the amount of the lien is 1 000 000 EUR, and the property value is 1 300 000 EUR The exposure value of the exposure is therefore 900 000 + 250 000 * 0,4 = 1 000 000 EUR Thus, there is no part of the exposure exceeding the amount of the lien on the property based on the exposure value.   Note: There was a Q&A on a related topic regarding Article 125(2) of CRR before amendment by Regulation (EU) 2024/1623 - question ID 2014_705. We reckon, under the amended version of CRR, the exposure value calculated in accordance with Article 111 is the base to determine, which part of the exposure shall be assigned a risk weight of 20 % or 60 % respectively under Articles 125(1) and 126(1) and how high the remaining part of the exposure referred to in the last sentence of these paragraphs is.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7311

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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